Decree 255/2026/ND-CP on Tax Administration for Related Party Transactions – Key Changes
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Decree 255 on tax administration
27 July 2026
On 30 June 2026, the Vietnamese Government issued Decree 255/2026/ND-CP (hereinafter referred to as "Decree 255" or “the Decree”) on tax administration for related party transactions (“RPTs”), replacing Decree 132/2020/ND-CP ("Decree 132") and Decree 20/2025/ND-CP ("Decree 20/2025").
Decree 255/2026/ND-CP took effect on 1 July 2026 and applies from the 2026 corporate income tax (“CIT”) period. Overall, the Decree retains the existing transfer pricing compliance framework for RPTs, while introducing several important amendments to key regulations. In this Tax Alert, Forvis Mazars Vietnam provides an overview of the key changes under Decree 255 that may have significant implications for transfer pricing compliance in Vietnam.
The key changes introduced under Decree 255/2026/NĐ-CP:
- Establishing database priority hierarchy
- Expanding exemption threshold for Transfer Pricing Documentation
- Enhancing the regulatory framework for Country-by-Country Report ("CbCR")
- Strengthening tax administration and compliance support
How we can help?
Navigating Vietnam's evolving Tax and Legal environment requires timely insights and practical guidance. Our Tax and Legal specialists can support businesses in assessing compliance risks, optimizing tax positions, and adapting effectively to regulatory changes.
Please refer to the full updates in the Download section below.
Contacts
Da Nguyen Minh Partner, Tax
Dzung Dang Partner, Legal
Christophe Cougnaud Partner, Legal
3 Aug 2026
Decree 253 & Circular 87 on PIT
On 30 June 2026, the Vietnamese Government and the Ministry of Finance issued Decree No. 253/2026/ND-CP and Circular No. 87/2026/TT-BTC on Personal Income Tax (“PIT”), providing important clarifications on employment income, tax deductions, withholding obligations, and PIT finalization procedures.
27 Jul 2026
Decree 255 on tax administration
On 30 June 2026, the Vietnamese Government issued Decree 255/2026/ND-CP (hereinafter referred to as "Decree 255" or “the Decree”) on tax administration for related party transactions (“RPTs”), replacing Decree 132/2020/ND-CP ("Decree 132") and Decree 20/2025/ND-CP ("Decree 20/2025").
27 Jul 2026
Decree 254 & Circular 91
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Vietnam continues to refine its tax and legal framework with a series of official letters issued in June 2026. This month's newsletter covers key developments across corporate income tax, value added tax, personal income tax, foreign contractor tax and tax treaty relief, as well as newly issued legal documents on trade promotion and payment deadline extensions. These updates matter to businesses assessing...
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