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New transfer pricing regulations on APAs released

05 July, 2021

On 18 June, the Ministry of Finance issued Circular 45/2021/TT-BTC, setting out new rules on Advance Pricing Agreements in Vietnam. 

Circular 45 takes effect from 3 August, and replaces the existing APA Circular 201 issued in 2013.

Although said Circular 201 was issued 8 years ago, there has been little progress made on getting APAs in place since then, with only a handful being finalized and a few others making slow progress at present. APAs can be very useful, to taxpayers and tax authorities alike, in providing certainty, and this new circular seems to reflect the Government’s keenness to get these working better in Vietnam and more in line with practice in other countries.

We outline some of the key points below. 

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Get in touch

Nguyen Thanh Trung

Partner, Tax Services Leader, PwC Vietnam

Tel: +84 28 3823 0796

Nguyen Huong Giang

Partner, Tax Services, PwC Vietnam

Tel: +84 24 3946 2246

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