Following the introduction of the Advanced Pricing Agreement (APA) regime under the Amended Tax Administration Law, Amended Corporate Income Tax Law and Decree 83/2013/ND-CP dated 22 July 2013, the Ministry of Finance (MOF) has issued Circular 201/2013/TT-BTC dated 20 December 2013 providing detailed guidance on Advance Pricing Agreements (Circular 201) which will be effective from 5 February 2014…