Vietnam has introduced important changes to its transfer pricing regulations under Decree No. 255/2026/ND-CP, effective from 1 July 2026 and applicable from the 2026 Corporate Income Tax (CIT) year. The new Decree replaces the previous transfer pricing regulations under Decree 132/2020/ND-CP and Decree 20/2025/ND-CP, in line with the revised tax administration framework and international standards, including the OECD’s Base Erosion and Profit Shifting (BEPS) framework.
While many of the fundamental transfer pricing principles remain unchanged, the new regulations introduce several important updates that affect how businesses identify related parties, prepare transfer pricing documentation, manage Country-by-Country Reporting (CbCR) obligations, and support their transfer pricing positions during tax audits. The changes are particularly relevant to Vietnamese companies and foreign-invested enterprises that have related-party transactions, multinational group structures, or cross-border financing arrangements. Businesses should therefore review their existing arrangements and compliance processes early rather than waiting until the 2026 tax filing season.
Summary of the key changes
The most important developments under Decree 255 include:
- Expanded related-party relationships: Certain borrowing and lending transactions with individuals who manage, control, or have specified relationships with an enterprise may create a related-party relationship.
- Priority of transfer pricing databases: Taxpayers and tax authorities should prioritize publicly available databases, followed by commercial databases and tax authority databases.
- Updated CbCR threshold: The Country-by-Country Reporting threshold is changed from VND 18,000 billion to EUR 750 million, based on the group’s consolidated global revenue in the financial year preceding the reporting year.
- CbCR filing requirements: Vietnamese entities may be exempt from local CbCR filing where the report is filed overseas and automatically exchanged with Vietnam. Local filing may arise if the relevant report is unavailable through an effective information-exchange mechanism.
- CbCR notification: Form 01/TB-BCLN is generally submitted only once when the obligation first arises. Changes must be reported within 90 days, while the CbCR filing deadline is 12 months after the end of the Ultimate Parent Entity’s financial year.
- Broader documentation exemption: The annual revenue threshold for the relevant transfer pricing documentation exemption increases from below VND 200 billion to below VND 500 billion, and the “simple functions” condition is removed.
- Use of CbCR information: Tax authorities may use CbCR information for risk assessment and information exchange, but not to directly adjust or impose related-party transaction prices.
- Transitional interest treatment: Eligible interest expenses carried forward under Decree No. 20/2025/ND-CP may continue to be carried forward for the remaining permitted period.
Implications for businesses
Businesses should reassess their related-party relationships
Many businesses traditionally focus on ownership relationships when assessing transfer pricing obligations. However, under Decree 255, borrowing, lending, borrowing-in-kind, or lending-in-kind transactions between an enterprise and an individual who manages or controls the enterprise, or an individual with a specified family relationship, may create a related-party relationship if the transaction value is at least 10% of the owner’s contributed capital at the time the transaction arises during the tax period.
A transaction that was previously considered outside the transfer pricing framework may now require closer analysis. Once a related-party relationship is established, the business may have additional reporting and documentation obligations. Businesses should conduct a comprehensive review of shareholder structures, internal financing arrangements, loans between companies and key individuals, guarantees and similar funding arrangements. A review should focus not only on the legal form of the transaction, but also on the relationship between the parties involved.
Transfer pricing benchmarking will require a clearer approach to data sources
Decree 255 establishes an explicit order of priority for databases and information used in transfer pricing analysis. For businesses preparing benchmarking studies, the choice of data source can affect the reliability and defensibility of their transfer pricing position. Companies that have historically relied heavily on commercial databases or regional comparables may need to reconsider whether other sources should be reviewed first under the new hierarchy. The Decree also retains the existing approach to selecting comparable companies, generally prioritising internal comparables before domestic and then regional comparables.
Businesses should review the data sources used in existing benchmarking studies and ensure that future transfer pricing documentation reflects the new hierarchy.
Country-by-Country Reporting is now more closely aligned with international standards
The EUR 750 million threshold brings Vietnam’s CbCR threshold in line with the internationally recognised threshold used under the OECD’s CbCR framework. This creates greater consistency for multinational groups operating across multiple countries.
Multinational groups should not assume that their previous CbCR assessment remains valid under the new regime. The change in threshold may affect whether a group falls within the reporting requirements, especially in light of exchange rate fluctuations or the differences between the previous VND threshold and the EUR-based threshold. Businesses should also consider the structure of their group, including the location of the Ultimate Parent Entity and whether another group entity acts as a surrogate filing entity.
More businesses may qualify for a transfer pricing documentation exemption
Decree 255 increases the relevant annual revenue threshold for a transfer pricing documentation exemption from below VND 200 billion to below VND 500 billion in specified circumstances. This could reduce the compliance burden for certain businesses with related-party transactions.
However, an exemption from preparing transfer pricing documentation does not necessarily mean that the business is exempt from all transfer pricing obligations. Eligibility depends on the specific conditions set out in the Decree. Businesses should carefully assess factors such as annual revenue, whether the business generates revenue or incurs expenses related to intangible assets, applicable profitability requirements, and the nature and scale of related-party transactions. Finance and tax teams should reassess their 2026 position rather than automatically applying the previous rules.
What businesses should review before 2026 CIT finalization
As Decree 255 applies from the 2026 corporate income tax year, businesses with related-party transactions should incorporate the new requirements into their 2026 tax compliance process. Before finalizing the 2026 CIT return, businesses should consider the following:
- Reassess related-party relationships, particularly those involving financing with shareholders, directors, managers, or connected individuals.
- Review 2026 related-party transactions and ensure they are correctly identified and classified.
- Assess whether your business qualifies for the revised TP documentation exemption and whether the relevant conditions are met.
- Review your benchmarking approach and ensure the data sources follow the new priority hierarchy.
- Confirm whether the EUR 750 million threshold, local filing, and notification requirements apply to your group.
- Review carried-forward interest expenses and confirm whether they remain eligible for deduction under the transitional rules.
- Ensure that information is consistent across TP documentation, financial statements, CIT filings, and CbCR where applicable.
Completing these reviews before the 2026 CIT finalization can help businesses identify potential compliance issues early and avoid last-minute adjustments or documentation gaps.
Conclusion
The introduction of Decree No. 255/2026/ND-CP represents an important development in Vietnam’s transfer pricing landscape. While some businesses may benefit from reduced documentation requirements, the expanded scope of related-party relationships and enhanced reporting framework require careful assessment and proactive planning. For local and foreign-invested enterprises operating in Vietnam, proactive planning can help reduce compliance risks and avoid last-minute challenges. With the 2026 tax year already underway, now is an appropriate time to review your transfer pricing position and prepare for the new requirements.
Contact RBA Vietnam to discuss how the new transfer pricing regulations may affect your business and how we can support your compliance and tax planning needs.
Disclaimer:
This publication has been prepared for general guidance only and should not be relied upon as accounting, tax, legal, or other professional advice. Businesses are encouraged to seek advice tailored to their specific circumstances.
