Decree 255/2026/NĐ-CP on tax administration for related party transactions: Key updates and practical considerations
07 July, 2026
The Vietnam Government has issued Decree 255/2026/NĐ-CP ("Decree 255") on tax administration for related-party transactions, replacing Decree 132/2020/ND-CP and Decree 20/2025/ND-CP. The new Decree retains the core transfer pricing framework while introducing targeted refinements in several areas of administration and compliance.
Key updates include a prescribed hierarchy for benchmarking data sources, revisions to the TP documentation exemption regime, and more detailed Country-by-Country Reporting (“CbCR”) requirements. Decree 255 also introduces transparency obligations for tax authorities regarding CbCR exchange mechanisms, which may affect the practical application of local filing requirements.
Decree 255 is effective from 1 July 2026 and applies from the 2026 corporate income tax period.
This Newsbrief summarises the key changes under Decree 255 and outlines practical considerations for taxpayers.
