31 July, 2026
On 21 July 2026, the Government issued Decree 291/2026, amending Decree 125/2020 on administrative penalties relating to tax and invoices. Decree 291 took effect immediately upon issuance.
Decree 291 introduces new penalties for failing to provide information requested by the Vietnamese tax authorities for tax information exchange purposes. Country-by-Country Report (“CbCR”) is one of the tax documentation requirements that falls within the scope of tax information exchange. Accordingly, non-compliance with the relevant filing and notification obligations under the three-tiered transfer pricing documentation framework may be subject to the new penalty regime introduced under Decree 291.