Significant steps made in related party transactions
Related party transactions remain one of the areas most closely scrutinised by Vietnam s tax authorities during tax audits
Between 2020 and 2025, Vietnamese tax authorities reviewed over 5,000 enterprises involved in related-party transactions, leading to additional assessments, recoveries, and penalties totaling more than $461.5 million. The Vietnamese government is tightening rules on related parties, focusing on economic substance, transparency, and transfer pricing compliance.
Decree No.255/2026/ND-CP, effective for the 2026 CIT tax period, expands the definition of related parties to include certain borrowing and lending arrangements with controlling individuals and relatives. The decree also broadens exemption circumstances for transfer pricing documentation, yet enterprises under these exemptions must still declare related-party transactions.
Vietnam establishes a national database as an official source for declaring, determining, and administering related-party transaction prices, along with a priority order for databases used in transfer pricing analyses. Country-by-Country Reporting (CbCR) requirements have been revised to align with OECD recommendations, with a reporting threshold of €750 million ($865 million) for consolidated global revenue.
Enterprises should scrutinize related-party transactions, ensure accurate disclosure, maintain robust supporting documentation, and assess commercial justification for transactions, in line with the new framework.
Written by urgent.news from Vietnam Investment Review's reporting — not their text. Machine-written — may contain errors; check the original before relying on it.
