Circular 95/2026/TT-BTC on the application of the Advance Pricing Agreement framework
13 July, 2026
On 1 July 2026, the Ministry of Finance issued Circular 95/2026/TT-BTC (“Circular 95”), providing updated guidance on the application of Vietnam’s Double Tax Treaties, Mutual Agreement Procedures (“MAP”) and Advance Pricing Agreements (“APAs”). Circular 95 took effect on 1 July 2026. This Circular replaces Circular 205/2013/TT-BTC on the implementation of tax treaties and Circular 45/2021/TT-BTC on APA.
APA applications submitted before the effective date of this Circular but not yet concluded will be processed under the new Law on Tax Administration and Circular 95.
This NewsBrief is solely focused on highlighting key APA-related changes and enhancements under Circular 95, as well as areas requiring further consideration.
