Vietnam: Amendments to transfer pricing framework

Decree No. 255/2026/ND-CP introduces amendments to Vietnam’s transfer pricing framework effective July 1, 2026, and applicable from the 2026 corporate income tax period onwards. The amendments include:

• Increase in revenue threshold for exemption from transfer pricing documentation from VND 200 million to VND 500 million for taxpayers that do not generate revenue or incur expenses from the exploitation of intangible assets
• Replacement of country-by-country (CbC) reporting threshold of VND 18 trillion with the internationally recognized €750 million global consolidated revenue threshold
• Introduction of new, one-time notification requirement for taxpayers whose ultimate parent entity (UPE) or surrogate parent entity files a CbC report outside of Vietnam
• Establishment of official order of priority for data sources used in transfer pricing analysis, with public and official sources given the highest priority, followed by commercial databases, and then tax management databases
• Permission for tax authorities to publish industry-wide profit indicators by sector or taxpayer group, which can be used as a reference point for determining arm's-length pricing and likely will influence risk assessment and tax audits
• Emphasis on more data-driven and risk-based approach to tax administration, with a focus on inter-agency data sharing and pre-audit consultations
• Consolidation and clarification of rules for defining related parties in financing transactions, with specific exclusions for arrangements involving credit institutions and certain state-owned debt resolution entities

The decree replaces Decree No. 132/2020/ND-CP and Decree No. 20/2025/ND-CP.

Read a July 2026 report prepared by the KPMG member firm in Vietnam