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Vietnam Draft Decree on Transfer Pricing

11 October 2016

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Proposed Changes

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Vietnam

The Vietnamese Ministry of Finance is consulting on a draft decree to update the country's transfer pricing regulations. Some of the main aspects of the draft decree include: The definition of related parties, including an increase in the direct or indirect ownership threshold from 20% to 25% and certain other changes; Principles and procedures for comparative analysis; The acceptable transfer pricing methods, which include: Comparable uncontrolled price method; Resale price method; Cost plus method; Comparable profit method; Profit split method; An interest expense deduction limit equal to 20% of EBITDA; Principles for determining the deductible expenses for services provided between...