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Vietnam Amends Transfer Pricing Decree Including New Rules on the Treatment of Certain Parties as Related and a New Transfer Pricing Disclosure

|Approved Changes|Vietnam
Vietnam

The Vietnam government has issued Decree No. 20/2025/ND-CP, which amends Decree No. 132/2020/ND-CP on transfer pricing. One of the key changes concerns the treatment of lenders or guarantors as related parties. In general, a company that guarantees or provides a loan to another company is considered a related party (i) the total outstanding loans owed by the borrower amount to 25% or more of t…

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