Vietnam's General Department of Taxation has released updated guidelines on transfer pricing documentation for fiscal years beginning in 2026. These guidelines bring Vietnam closer to international standards while introducing some unique local requirements.
Multinational enterprises with operations in Vietnam are now required to prepare three-tier documentation: a master file, a local file, and a country-by-country report. The thresholds for filing have been adjusted, and the deadline for submission has been moved to align with the annual CIT return filing.
One significant change is the introduction of benchmarking requirements for comparable companies. Taxpayers must now provide a detailed economic analysis justifying their transfer pricing methods, with particular emphasis on the selection of comparable transactions.
The penalties for non-compliance or late filing of transfer pricing documentation have been substantially increased. Enterprises found to have insufficient documentation may face adjustments to their taxable income, plus interest and penalties.
We advise multinational enterprises operating in Vietnam to begin preparing their transfer pricing documentation well in advance of the filing deadline and to consider engaging specialist transfer pricing advisors to ensure compliance with the updated requirements.