Vietnam Issues Decree on New Transfer Pricing Rules Including CbC Reporting

The Vietnamese government has announced the issuance of Decree No. 20/2017/ND-CP, which sets out the principles, methods, and procedures for determining transfer pricing, including the adoption of guidance resulting from the BEPS Project. The Decree also introduces new transfer pricing documentation requirements based on BEPS Action 13. Key points of the decree include:

• A new definition of related parties, including an increase in the direct or indirect ownership threshold from 20% to 25%;
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