A key feature of Vietnam’s transfer pricing regime is a cap on the tax deductibility of interest, which applies in many cases and limits tax deductible interest to 20% of a taxpayer’s EBITDA.
According to the website of the Ministry of Finance, on 12 December 2019, a draft decree was released for public comment. This draft regulation proposes changes to the cap on interest tax deductibility in the current transfer pricing Decree 20.
Richard J. Irwin
Partner, Tax and Legal Services, PwC Vietnam
Tel: +84 28 3823 0796