Vietnam Drafting New Transfer Pricing Decree Including Revised CbC Report Submission Requirements

The Vietnamese Ministry of Finance has announced that it is drafting a new decree to modernize tax management for related party transactions (transfer pricing), which is intended to take effect on 1 July 2026, along with the new Law on Tax Administration (Law No. 108/2025/QH15). This draft decree aims to align local regulations with international standards, specifically the OECD's Base Erosion and Profit Shifting (BEPS) framework. One of the more notable changes is requiring the submission …