Edwin Vanderbruggen

Scholarly Articles

Which Transfer Pricing Method for Which Activity? The OECD Experience and Comparisons with Vietnam

This is the fifth part in a series of contributions focused on analyzing Vietnam’s current key transfer pricing regulation Decree 132 from the perspective of the 2022 Transfer Pricing Guidelines (“TPG”) of the Organization for Economic Cooperation and Development (“OECD”).

Feb 06, 2020

Hierarchy or Most Appropriate Method for Transfer Pricing? The OECD Experience and Comparisons with Vietnam

This is the fourth part in a series of contributions focused on analyzing Vietnam’s current key transfer pricing regulation Decree 132[1] from the perspective of the 2022 Transfer Pricing Guidelines (“TPG”) of the Organization for Economic Cooperation and Development (“OECD”). Flexibility or structure? Between 1995 and 2010, the TPG featured a qualified hierarchy of methods […]

Feb 06, 2020

Comparables for Transfer Pricing: The OECD Experience and Comparisons with Vietnam

This is the second part in a series of contributions focused on analyzing Vietnam’s current key transfer pricing regulation Decree 132[1] from the perspective of the 2022 Transfer Pricing Guidelines (“TPG”) of the Organization for Economic Cooperation and Development (“OECD”). Internal or external comparables? When a taxpayer has engaged in similar transactions with both related […]

Feb 06, 2020

The OECD Experience on Transfer Pricing and Comparisons with Vietnam: Who Are Related Parties?

This is the first part in a series of contributions focused on analyzing Vietnam’s current key transfer pricing regulation Decree 132[1] from the perspective of the 2022 Transfer Pricing Guidelines (“TPG”) of the Organization for Economic Cooperation and Development (“OECD”). The purpose is to highlight different experiences, possible differences in approach and emphasis with respect […]

Feb 06, 2020

Vietnam

Which is more attractive for structuring investments into Vietnam: The (New) Hong Kong-Vietnam or the Singapore-Vietnam Double Taxation Agreement?

On 16 December 2008, the Government of the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”), and the Government of the Socialist Republic of Vietnam (“Vietnam”) have signed their first double taxation agreement (hereafter “HK-VN DTA”)[1]. The HK-VN DTA is bound to generate much interest from practitioners and from the […]

Jul 24, 2012

Vietnam's Implementation of the OECD Transfer Pricing Guidelines: the OECD Experience on Transfer Pricing and Comparisons With Vietnam

The decision of the Indian Supreme Court in the Vodafone case earlier this year (January 23, 2009), with tax regulations on the same issue in Indonesia and China, has woken up the Asian tax community to a significant new tax problem—the offshore transfer of shares.

Mar 01, 2010

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About

Edwin, a senior partner at VDB Loi, has over 30 years of experience in tax and legal matters. He advises international clients, consults for major organizations like the IFC and ADB, and has a strong academic background with awards for his publications. His expertise covers Southeast Asian legal reform and taxation.