Seminar on Transfer Pricing, Double Taxation Avoidance Agreements and Global Minimum Tax

Seminar on Transfer Pricing, Double Taxation Avoidance Agreements and Global Minimum Tax

On May 15, 2025, at the Binh Duong Provincial Convention and Exhibition Center, Tri Thuc Viet Co., Ltd. (TTV), in collaboration with the Korea Chamber of Commerce and Industry (KOCHAM), organized a specialized seminar on Transfer Pricing, Double Taxation Avoidance Agreements, and the Global Minimum Tax.

We were honored by the presence of KOCHAM’s Vice Chairman, KOCHAM’s Director, members of KOCHAM Binh Duong, and leaders, chief accountants from over 100 loyal partners and clients of TTV.

The keynote speaker of the seminar was Ms. Nguyen Thi Hanh – Former Deputy Director General of the General Department of Taxation of Vietnam. Ms. Hanh has over 34 years of experience in the taxation sector and currently serves as a lead lecturer providing training to tax officers working at tax departments in all 63 provinces and cities across Vietnam.

She has been accompanying Tri Thuc Viet for more than 10 years, providing training on tax policies and professional knowledge for both our clients and employees. In addition, she has also supported us in protecting the legitimate tax rights of several clients in recent years.

On the topic of Transfer Pricing, Ms. Nguyen Thi Hanh shared in-depth, practical knowledge with illustrative examples relating to transfer pricing matters. She highlighted common mistakes made by enterprises in identifying related parties and in preparing and filing the Transfer Pricing Documentation and Disclosures.

Ms. Hanh also enthusiastically answered questions from attendees with clear and detailed explanations, addressing specific situations that TTV’s clients have encountered over time.

On the subject of Double Taxation Avoidance Agreements (DTAAs) and the Global Minimum Tax, Ms. Hanh explained the concept of legal double taxation (taxation on the same source of income or on the same taxpayer in different jurisdictions). She guided attendees on how to determine and calculate tax obligations, and described methods for avoiding double taxation (Tax exemption method, tax credit method, lump-sum tax credit method, indirect tax credit method).

Regarding the Global Minimum Tax, Ms. Nguyen Thi Hanh presented the cases in which multinational enterprise (MNE) groups are subject to global minimum tax obligations in Vietnam — specifically, when a constituent entity in Vietnam enjoys an effective corporate income tax (CIT) rate lower than the global minimum rate of 15%.

She also clarified the scope of entities subject to global minimum taxation, namely constituent entities of an MNE group whose consolidated revenue, as reported in the ultimate parent entity’s consolidated financial statements, amounts to EUR 750 million or more in at least two out of the four fiscal years immediately preceding the fiscal year in which the tax obligation is determined, except for certain exempted cases.

Although time was limited, Ms. Hanh delivered a concise yet comprehensive presentation, ensuring clarity and actively responded to all questions.

As many of the attending business owners were Korean, we provided simultaneous interpretation in Korean to ensure professionalism and enhance communication.

The organization and execution of the seminar were handled entirely by TTV staff, who have successfully organized similar events over the past 10 years. This time, they performed excellently and professionally, earning high praise from participants, especially from KOCHAM leadership and Korean business owners.