Vietnam's Ministry of Finance has issued Circular 45/2021/TT-BTC of 18 June 2021, which provides new guidelines on advance pricing agreements (APAs). Circular 45/2021 updates and replaces Circular 201/2013/TT-BTC, taking into account Vietnam's latest transfer pricing rules including, in particular, the latest decree on transfer pricing, Decree No. 132/2020/ND-CP. In this regard, several sections of Circular 45 refer to Decree No. 132/2020/ND-CP, including in terms of: Subjects eligible for entering into APAs, which includes corporate income taxpayers conducting transactions with related parties as per Article 5 of Decree No. 132/2020/ND-CP (generally 25% ownership); Transactions that may be covered by an APA,...