Joseph Vu
Partner
Head of Global Transfer Pricing Services
KPMG in Vietnam
Joseph Vu
Partner, Head of Global Transfer Pricing Services, KPMG in Vietnam
Joe is the Global Transfer Pricing Services (GTPS) Leader for KPMG in Vietnam with a team of over 70 transfer pricing professionals. Joe brings tremendous knowledge and experience through his 21 years of transfer pricing consulting. Over his professional career, he worked in the US, Japan and China before relocating to his native Vietnam in 2015.
Joe maintains strong working relationship with the Vietnam’s General Department of Taxation (“GDT”) and has frequently been invited as guest speaker in various forums and events held by the government to share insights on transfer pricing matters, including commentary on legislative reforms, providing technical training, and sharing of international practices. Notably, Joe was invited by the delegation from Vietnam’s Ministry of Finance / GDT to meet with the OECD, UN and World Bank representatives in Europe to share insights on administration of transfer pricing for developing countries.
Selected Experience:
- Involved in a wide range of transfer pricing engagements, including compliance, group pricing policy development, and tax dispute resolution.
- Specializes in tax controversy services and negotiating with tax authorities on complex cases.
- Supported the first six bilateral APAs in Vietnam and the first MAP case on cross-border transfer pricing disputes.
- Regularly collaborates with GDT and speaks at government-organized transfer pricing events.
Tran Thi Thuy Ha
Partner
Global Transfer Pricing Services
KPMG in Vietnam
Tran Thi Thuy Ha
Partner, Global Transfer Pricing Services, KPMG in Vietnam
Ha has been with KPMG for 16 years, including with KPMG in Australia, Sydney Global Transfer Pricing Services group under an international assignment.
Ha has advised a wide range of multinationals from Australia, Europe, the US, and Asia Pacific region in diverse industries including consumer/industrial goods, media and entertainment, financial services, electronics, forwarding and logistics, and information technology, on tax, customs, and transfer pricing compliance and planning, and inbound investment.
Ha’s sector experience includes transfer pricing, trade & customs, and international tax.
Ha was the Engagement Partner of several dozens of transfer pricing and customs audit and dispute resolution engagements where many of the cases were resolved successfully either in the audit or appellation. She was initiated to speak to the central and provincial tax authorities on international best practice of transfer pricing audits and local practical issues.
Ha was directly involved in consultation with the General Department of Taxation and Ministry of Finance in relation to the Decree 20/2017/ND-CP and Decree 132/2020/ND-CP on Transfer Pricing, and Circular 45/2021/TT-BTC on Advance Pricing Agreement, including the consideration of practical issues in local transfer pricing audits of multinational corporations operating in Vietnam.
Expertise:
- Global Transfer Pricing Services
- International Tax
- Value Chain Management
- Trade & Customs
03 July 2025
By Joseph Vu & Ha Tran, Global Transfer Pricing Services, KPMG in Vietnam
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As global trade tensions rise, Vietnam’s export-oriented economy faces fresh pressure from a wave of tariff increases, most notably from the United States. While much of the focus has been on direct impacts such as higher costs and reduced competitiveness, experts now warn of deeper implications tied to transfer pricing (TP)—and a growing risk of tax disputes if businesses don’t adapt quickly.
Vietnam’s Strategic Position in Global Supply Chains
Vietnam has become a crucial manufacturing hub for multinational corporations in sectors like electronics, apparel, and consumer goods. With a strong export base and increasing integration into global value chains, the country is particularly sensitive to sudden changes in trade policy.
“If countries like the U.S. impose high tariffs on Vietnamese goods, it doesn’t just hurt short-term profit margins—it can also throw off the pricing structures between related companies across borders,” said Joseph Vu, Head of Global Transfer Pricing Serivices, KPMG in Vietnam. “That’s where transfer pricing comes in.”
Short-Term Shocks vs Long-Term Shifts
| Short-Term Impacts | Long-Term Considerations |
|---|---|
| Sudden cost spikes due to new tariffs | Possible relocation of supply chains |
| Disrupted U.S. orders or thinner margins | Diversification to non-U.S. markets |
| Quick fixes like rush shipments or price hikes | Need for reinvestment and new buyers |
| Outdated TP arrangements | Fresh pricing logic and documentation needed |
One common example: A Vietnamese subsidiary sells to its U.S. parent company. With new tariffs in place, should the Vietnamese entity lower its prices to maintain competitiveness? Or should the U.S. side absorb the extra cost? Either choice affects where the profit—and tax liability—lands.
Why Transfer Pricing Now Matters More Than Ever
Transfer pricing, which governs how profits are allocated among related entities in different countries, is coming under intense scrutiny. Tariffs reduce total profits, and tax authorities—both in Vietnam and abroad—are closely watching how those profits are shared.
In Vietnam, tax officials may challenge exporters who report lower margins due to tariffs, especially if there's no supporting documentation. If foreign authorities take a different view, businesses may face double taxation—a situation where the same income is taxed in two countries.
Documentation: The First Line of Defense
Vietnamese tax authorities have already been ramping up TP audits in recent years. Tariff-induced profit drops or pricing changes will trigger even closer reviews.
Companies should act now to:
- Clearly document why prices changed (e.g., new tariffs, supply shifts)
- Run scenario analyses to explain how costs and profits are shared
- Consider Advance Pricing Agreements (APAs) to lock in treatment with key trade partners
Practical Steps for Vietnamese Exporters
| Action | Why It’s Important |
|---|---|
| Re-evaluate TP policies | Align with current costs and profit pressures |
| Strengthen TP documentation | Avoid disputes and defend pricing structures |
| Monitor global tariff changes | Prepare for future cost and price volatility |
| Explore bilateral APAs | Reduce risk of double taxation |
Looking Ahead
Vietnam’s integration into global trade is a strength—but also a vulnerability. As geopolitical and economic uncertainties grow, exporters must not only navigate cost pressures, but also adjust their internal pricing strategies to stay compliant and competitive.
“In the end, it’s about being proactive,” said Joseph Vu. “Those who wait too long to update their pricing models and documentation will face the biggest risks—not just from tariffs, but from the tax authorities at both ends of the value chain.”