Draft Circular on the application of the Advance Pricing Agreement framework
May 2026
The Vietnam Ministry of Finance has released a draft Circular (the “Draft Circular”) for public consultation. The Draft Circular is intended to replace Circular 205/2013 on double taxation agreements (DTAs), Circular 45/2021 on advance pricing agreements (APAs), and the mutual agreement procedure (MAP)-related provisions under Circular 80/2021. It will consolidate guidance on DTAs, MAP and APAs into a single regulatory instrument, and is expected to take effect on 1 July 2026.
This Newsbrief is solely focused on highlighting key APA-related changes and enhancements under the Draft Circular, as well as areas requiring further clarification and consideration.
