The Ministry of Finance has issued Circular 66/2010/TT-BTC, which amends the current transfer pricing regulation Circular 117/2005/TT-BTC. Circular 66 will take effect on 6 June 2010. Scope Circular 66 limits the application to transactions between enterprises and their affiliated parties and, unlike Circular 117, does not cover individuals. Related parties Under Circular 66, the definition of "related parties" includes limited liability companies. Under Circular 117, there was a test of affiliation whereby a 20% ownership of "total assets" in another company will render the parties as being related. Circular 66 has replaced this test with these criteria in determining related...