Draft Decree on Transfer Pricing and Direct Tax Administration of Related-Party Transactions

Vietnam’s Ministry of Finance released a Draft Decree on tax administration of enterprises with related-party transactions which covers transfer pricing rules and some other aspects of direct taxation. The authors analyse key aspects of the Draft Decree and discuss the appropriateness and possible impacts of the proposed changes on Vietnam-based business operations in light of the OECD BEPS Project, existing transfer pricing rules, practical enforcement and expected developments in Vietnam.