Vietnam: MCAA for exchange of CbC reports signed; amendments to transfer pricing regulations

Report on recent transfer pricing developments in Vietnam

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February 20, 2025

Vietnam on January 3, 2025, signed the Multilateral Competent Authority Agreement (MCAA) for the automatic exchange of country-by-country (CbC) reports. As of February 13, 2025, Vietnam has activated exchange relationships with 29 jurisdictions.

In addition, the government on February 10, 2025, issued Decree 20/2025/NĐ-CP, amending specific provisions of Decree 132 effective March 27, 2025, and applicable from tax year 2024 onwards. Key amendments include revised definitions of related party relationships, expanded responsibilities for the State Bank of Vietnam, updated transfer pricing declaration forms, and transitional guidance on interest deductibility caps.

Read a February 2025 report prepared by the KPMG member firm in Vietnam

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