The Vietnam government has issued Decree No. 132/2020/ND-CP, which revises and replaces Decree No. 20/2017/ND-CP on transfer pricing. Key points of the new Decree include the following:
- It is explicitly provided that commercial databases may be used by both taxpayers and the tax authority for comparables for benchmarking purposes, while the use of internal (secret) comparables by the tax authorities is limited to cases where the taxpayer has not fully met transfer pricing compliance require…