20. Vietnam
<Monetary threshold for LF preparation>
Applicable if none of the following exemption criteria are met:
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Revenue is less than VND 50 billion and related-party transaction value is less than VND 30 billion.
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The taxpayer is covered by an APA and has submitted the annual report.
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The taxpayer performs only routine functions, has no income or expenses from the use of intangible assets, has total revenue of less than VND 200 billion, and has EBIT margins of at least 5% for distribution, 10% for manufacturing, and 15% for processing.
<Preparation deadline>
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Within 90 days from the end of the fiscal year (i.e., the corporate income tax return filing deadline).
<Submission deadline>
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Within 30 days of a request by the tax authority.
<Language>
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Vietnamese
<Penalty>
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Vietnam imposes penalties for transfer pricing non-compliance, including fines of VND 8–15 million for missing TP forms, a 20% penalty on underpaid tax due to incorrect declarations, daily interest of 0.03% on late payments, and up to three times the unpaid tax for tax evasion.
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Reference: Decree No. 132/2020/ND-CP（Vietnamese）
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