Vietnam's New Transfer Pricing Decree Includes Revised CbC Reporting and Transfer Pricing Documentation Requirements

Vietnam has published Decree No. 255/2026/ND-CP, originally issued on 30 June 2026. The Decree is effective from 1 July 2026, along with the new Law on Tax Administration (Law No. 108/2025/QH15). Decree No. 255/2026/ND-CP replaces Decree No. 132/2020/ND-CP and Decree No. 20/2025/ND-CP, aligning local regulations with international standards, specifically the OECD's Base Erosion and Profit Shifting (BEPS) framework.

As previously reported, one of the more notable changes is requiring the su…