Vietnam Gazettes Decree Amending Regulations on Related-Party Transactions, Transfer Pricing

The Vietnamese Official Gazette Feb. 23 published Decree No. 20/2025/ND-CP, amending the rules for identifying and documenting related-party transactions for corporate income tax and transfer pricing purposes. The decree includes measures: 1) clarifying that loans or guarantees from credit institutions aren’t considered related-party transactions if the credit institution doesn’t participate in the management, control, or capital of the borrower; 2) clarifying the exemption from transfer pricing documentation requirement for taxpayers with total revenue below 50 billion Vietnamese dong (US$1.9 million) and less than 30 billion dong (US$1.1 million) in related-party transactions; 3) clarifying the documentation exemption for qualifying activities generating ...