This thesis was shaped from Action 13 of the recent Base Erosion and Profit Shifting (BEPS) project adopted by the Organisation for Economic Co-operation and Development (OECD) and G20 countries to prevent profit shifting by multinational enterprises (MNEs). In response to the BEPS Action 13, New Zealand and Vietnam have recently introduced new transfer pricing rules. As little research has been done to examine the effects of the BEPS Action 13 on the transfer pricing landscape of respective countries, the main objective of this study is to understand how the New Zealand and Vietnamese governments have reacted to and adapted the BEPS Action 13 and what tax consultants and taxpayers in both countries think about the new transfer pricing regulations. This study is exploratory in nature. As such, a qualitative case study approach has been adopted using institutional theory as a theoretical framework. Semi-structured interviews were conducted with two tax officers and ten transfer pricing consultants in both countries to identify the differences and similarities, and to draw conclusions. Other sources of publicly available data were also used to support the study.

The findings of this study suggest that New Zealand as an OECD member and Vietnam as a non- OECD country have shared various common features regarding their responses to the BEPS Action 13. In general, the New Zealand and Vietnamese governments have intended to move closer to international standards by implementing several significant changes in their transfer pricing landscape following the BEPS Action 13. However, each country has also taken some different approaches in response to the BEPS Action 13. In addition, it is acknowledged that many tax consultants and taxpayers are not satisfied with some aspects of the new transfer pricing rules in New Zealand and Vietnam, posing the need for more transparency. This study also presents some theoretical and practical contributions for the current literature and policy makers. It also provides some implications for future research to tackle the BEPS issues.

All information presented in this thesis is up to date as of 30 June 2020.