I'm not sure about the specific Vietnamese context, but the core problem of extraterritorial enforcement (when the local sub can't coerce the HQ) was a key struggle in BEPS exactly because there's no established enforcement mechanism (https://phdskat.org/2016/08/03/beps-moving-away-from-separate-entity/ …)
Any #taxtwitter know the answer? e. g. UK local filing requirement is only for a 'UK CBCR' (UK entity & looking down its subsidiaries). Is there a mechanism to enforce local reporting looking upwards to group?https://twitter.com/MForstater/status/1027836413889458176 …
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Right... So that's why I'm wondering what the 'yay Vietnam has done *this*' story really means if *this*' isn't really possible?!
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