July 9, 2026
Vietnam - Revises Transfer Pricing Rules and CbC Reporting Framework
Summary
The Government of Vietnam issued Decree No. 255/2026/ND-CP on June 30, 2026, effective from July 1, 2026, revising Vietnam’s transfer pricing framework, including amendments to transfer pricing documentation exemption thresholds, country-by-country (CbC) reporting requirements, related-party transaction rules, and data source prioritization for transfer pricing analysis. The decree replaces Decree No. 132/2020/ND-CP and Decree No. 20/2025/ND-CP and applies from the 2026 corporate income tax period.
Key points
Increase in Transfer Pricing Documentation Exemption Threshold for Certain Taxpayers
The decree increases the revenue threshold for exemption from transfer pricing documentation requirements from VND 200 million to VND 500 million.
The exemption applies to taxpayers that do not generate revenue from or incur expenses related to the exploitation of intangible assets.
Revision of Country-by-Country Reporting Threshold
The decree revises the threshold for country-by-country (CbC) reporting obligations by replacing the previous Vietnam-specific threshold of VND 18 trillion with the internationally recognized threshold based on EUR 750 million of global consolidated revenue.
The revised threshold applies for determining entities subject to CbC reporting obligations under Vietnam’s transfer pricing regulations.
Introduction of Notification Requirement for Foreign CbC Reporting
The decree introduces a one-time notification requirement for taxpayers whose ultimate parent entity (UPE) or surrogate parent entity files a CbC report outside Vietnam.
The notification requirement applies to taxpayers subject to Vietnam’s CbC reporting-related obligations.
Transfer Pricing Documentation Preparation and Retention Requirements
The decree provides rules relating to the preparation and retention of transfer pricing documentation.
Taxpayers subject to transfer pricing documentation requirements are required to prepare and maintain transfer pricing documentation in accordance with applicable regulations.
The transfer pricing documentation is prepared based on the information and data available under the applicable transfer pricing framework.
Establishment of Data Source Priority Order for Transfer Pricing Analysis
The decree establishes an official priority order for information sources used in transfer pricing analysis.
The priority order provides that:
Publicly available and official sources have the highest priority;
Commercial databases are considered after public and official sources; and
Tax administration databases are considered subsequently.
Public and official sources include information obtained from publicly available and officially recognized sources under the applicable regulations.
The decree sets out the order of priority for selecting and using information sources in transfer pricing analysis.
Publication of Industry Profit Indicators by Tax Authorities
The decree permits tax authorities to publish profit indicators by industry sector or taxpayer group.
The published indicators may be used as reference information for determining arm’s-length pricing under Vietnam’s transfer pricing regulations.
CbC Reporting Exchange and Transparency Framework
The decree includes provisions relating to country-by-country reporting information and the exchange of CbC reporting information.
The provisions establish requirements relating to the submission, use, and exchange of CbC reporting information under Vietnam’s transfer pricing framework.
Risk-Based Tax Administration and Data Sharing Framework
The decree includes provisions relating to the use of data and information sharing among relevant authorities for tax administration purposes.
The provisions establish mechanisms relating to data-based tax administration and risk assessment activities.
Clarification of Related-Party Rules for Financing Transactions
The decree revises and clarifies the definition of related parties in financing transactions.
The amendments include specific exclusions for arrangements involving credit institutions and certain state-owned debt resolution entities.
Source:
Government of Vietnam, Decree No. 255/2026/ND-CP amending and supplementing a number of articles of Decree No. 132/2020/ND-CP on tax administration for enterprises having related-party transactions (June 30, 2026)
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Disclaimer:
This content is for general informational purposes only and does not constitute professional advice.
Information provided herein is based on publicly available sources as of the publication date and may be subject to change.
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