New Transfer Pricing Decree in Vietnam

Vietnam’s Government has recently released a Transfer Pricing (“TP”) Decree No. 20/2017/ND-CP (hereinafter refer to as “Decree 20” or “the Decree”), providing tax administration applicable to enterprises having related party transactions. The Decree shall take effect from 1 May 2017.

Significant changes of Decree No. 20/2017/ND-CP 

In comparison with the existing Circular No. 66/2010/TT-BTC (“Circular 66”), Decree 20 proposes some significant changes as follows:

  • Related party definition;
  • Comparability analysis and Transfer Pricing adjustments;
  • Transfer Pricing methodology;
  • Tax deductibility for related party expenses;
  • Three-tiered Transfer Pricing Documentation;
  • Timeline for Transfer Pricing Documentation preparation and submission; and
  • Transfer Pricing documentation compliance exemption


Our Support

With our extensive experience in Transfer Pricing planning and compliance, and as one of the major Transfer Pricing service providers in Vietnam, we are pleased to assist you to properly comply with the laws and regulations with the following services:

  • Review and analysis of Transfer Pricing risks and opportunities;
  • Full Transfer Pricing documentation;
  • Localization of Groups’ Master File into Vietnam-specific Transfer Pricing documentation;
  • Transfer Pricing benchmarking study;
  • Transfer Pricing audit defense; and
  • Advanced Pricing Agreement application.

Should you need more information or assistance, don’t hesitate to contact us at the following details.

Download the full issue in the PDF extension in English as below.

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Mazars Vietnam - Transfer Pricing Alert (ENG) - New TP Decree - 15 Mar 2017
Mazars Vietnam - Transfer Pricing Alert (ENG) - New TP Decree - 15 Mar 2017