Following the introduction of the Advanced Pricing Agreement (APA) regime under the Amended Tax Administration Law, Amended Corporate Income Tax Law and Decree 83/2013/ND-CP dated 22 July 2013, the Ministry of Finance (MOF) has issued Circular 201/2013/TT-BTC dated 20 December 2013 providing detailed guidance on Advance Pricing Agreements (Circular 201) which will be effective from 5 February 2014. Key points of Circular 201 have been summarized as follows. Scope of application An APA is available to Vietnamese corporate income taxpayers with related-party business transactions. There is no restriction on the taxpayer in terms of the size of business (such as...