Vietnam Issues New Rules on Tax Treaties, MAP, and APAs

Vietnam's Ministry of Finance (MoF) issued Circular 95/2026/TT-BTC in July 2026, which provides consolidated guidance on the implementation of double taxation agreements (tax treaties), the mutual agreement procedure (MAP) for resolving treaty-related tax disputes, and advance pricing arrangements (APAs), updating and replacing Circular No. 205/2013/TT-BTC and Circular No. 45/2021/TT-BTC. Key points are summarized as follows:

Tax Treaties

• It is clarified that the purpose of tax treaties i…