Updates On Transfer Pricing In Vietnam

Remarkable changes on transfer pricing have been introduced for enterprises that have controlled transactions, with an effective date of 1 May 2017.

The changes under Decree 20/2017/ND-CP include ownership threshold, transfer pricing (TP) documentation requirements and exemption of enterprises. Decree 20's effective date was 1 May 2017.

The decree was issued to enhance tax administration on transfer pricing, and requires more complicated TP documentation and provides stricter rules on deductibility of related party expenses. It provides tax management guidance on transfer pricing in enterprises, and is for enterprises that have controlled transactions. The decree replaces Circular 66/2010/TT-BTC.