In the case of the Coca-Cola Vietnam, which was decided in court on 27 November 2025, the tax authority found that Coca-Cola Vietnam’s related party transactions had not been priced at arm’s length.
Coca-Cola Vietnam had applied a profit-based method similar to TNMM. In its local transfer pricing file for the period from 2007 to 2015, the company’s own comparables produced an arm’s length interquartile range. However, for several years, particularly in 2007, 2011 and 2012, Coca-Cola Vietnam’s results were below that range. The low profitability was driven by intragroup purchases of key ingredients, especially concentrate imported from other group companies.
The tax authority used the company’s own benchmark to price the controlled transactions and increased the taxable profit for those years by approximately VND 362 billion.
The assessment was upheld in court.
While a transcript of the case has yet to be published, the Vietnamese Ministry of Finance has issued an official statement.
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