Issued in May 2017, Decree 20/2017/ND-CP (“Decree 20“) was an important milestone for Vietnamese tax system in its roadmap to adopt the recommendations from Organization for Economic Co-operation and Development (“OECD“) in relation to the initiative of Base Erosion and Profit Shifting (“BEPS“) for the purpose of better controlling the concept of Transfer Pricing in Vietnam.

Currently, the Government is collecting comments on the draft Decree amending Decree 20 for early issuance this year and expected to be applied from 1 July 2020. In order to support the enterprise community to have a broader overview on the context of Transfer Pricing in Vietnam as prescribed under Decree 20, Grant Thornton Vietnam would like to summarize some recent guidelines and answers from local tax authorities on this issue for your reference as follows:

1. Cases of exemption from preparation of Transfer Pricing Documentation and Forms
2. Determining the Corporate Income Tax (“CIT”) obligations for several types of RPTs incurred in the period
3. Determining the related parties being individuals
4. Determining interest expenses for CIT purposes for enterprises having related party transactions
5. Transactions of transferring intangible assets into Vietnam

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