Chile
The main corporate income tax rate is 20% for 2012. Under Law 20,630 amending the transfer pricing rules where an adjustment is made the shortfall is to be treated as a distribution and taxed at a 35% rate, with a penalty of 5%.
Law 20,630 effective from 1 January 2013 includes provisions for the negotiation of advance pricing agreements.
Japan
From 1 April 2013 earnings stripping rules apply to restrict the tax deduction on interest paid to related parties when this is disproportionate to income.
Vietnam
The Action Plan for transfer pricing management 2012-2015 provides that transfer pricing audits will be carried out in at least 20% of the cases chosen for general tax audit. High risk businesses targeted for audit would include export processing, construction, automotive and real property. A specialized transfer pricing team has been set up and a transfer pricing manual is to be developed.
