author_orbitax
Orbitax

Share This Article

Vietnam Amends Transfer Pricing Decree Including New Rules on the Treatment of Certain Parties as Related and a New Transfer Pricing Disclosure

26 February 2025

|

Approved Changes

|

Vietnam

The Vietnam government has issued Decree No. 20/2025/ND-CP, which amends Decree No. 132/2020/ND-CP on transfer pricing. One of the key changes concerns the treatment of lenders or guarantors as related parties. In general, a company that guarantees or provides a loan to another company is considered a related party (i) the total outstanding loans owed by the borrower amount to 25% or more of their contributed capital, and (ii) these loans make up over 50% of the borrower's total medium and long-term liabilities. Decree No. 20/2025/ND-CP excludes lenders or guarantors operating under the Law on Credit Institutions from being treated...