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Vietnam Publishes Transfer Pricing Decree Revisions for Consultation Including Relaxed Interest Deduction Restriction

25 June 2020

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Proposed Changes

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Vietnam

Vietnam's Ministry of Finance has reportedly published for consultation, draft revisions to Decree No. 20/2017/ND-CP on transfer pricing. One of the main revisions is an increase in the percentage of EBITDA restriction on interest expense deduction from 20% of EBITDA to 30%, with excess expense allowed to be carried forward up to five years. Other revisions include provisions for the use of a commercial database for comparables for benchmarking purposes, as well as amendments regarding the acceptable arm's length range.