On 24 February 2017, the Vietnamese government released transfer pricing decree No. 20/2017/ND-CP: “Providing the tax administration applicable to enterprises having controlled transactions” (Decree 20). Decree 20, which is effective from 1 May 2017, is understood to apply to taxpayers with a year end after this date.
Importantly, Decree 20 introduced many new transfer pricing reporting and documentation requirements as well as new guidance on the tax deductibility of service and interest expenses.
Taxpayers with December 2017 year ends are required to file the new transfer pricing declaration forms and prepare supporting documentation by March 31, 2018. This represents a significant change from prior years and is nine months earlier than the OECD recommended timeline, which may cause practical difficulties for many groups