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Vietnam Issues Revised Transfer Pricing Decree Including Relaxed Interest Deduction Restriction

01 July 2020

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Approved Changes

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Vietnam

Vietnam's Ministry of Finance has reportedly issued Decree 68/2020/ND-CP, which includes final revisions on transfer pricing, including an increase in the percentage of EBITDA restriction on interest expense deduction from 20% of EBITDA to 30%, with excess interest expense allowed to be carried forward up to five years. The increase to 30% applies retroactively from the 2019 tax year, although taxpayers are also allowed to apply the increase for the 2017 and 2018 tax years (the original 20% of EBITDA restriction first applied from May 2017). Taxpayers wishing to apply the revised restrictions for 2017 and 2018 are required to...