BDO's Update on Decree No. 255 providing guidance for of enterprises with related-party relationship

On 30 June 2026, the Government of Vietnam issued Decree No. 255/2026/ND-CP ("Decree 255") on tax administration for transactions between affiliated enterprises. Decree 255 replaces Decree No. 132/2020/ND-CP ("Decree 132") and Decree No. 20/2025/ND-CP ("Decree 20"), entering into force from 1 July 2026 and applying to the 2026 corporate income tax year onward.

While the overall transfer pricing framework remains unaltered, Decree 255 introduces several notable updates to related party definitions, transfer pricing documentation exemptions, transfer pricing databases, CbCR compliance requirements, and circumstances subject to transfer pricing adjustments.

This tax update summarises the key changes introduced under Decree 255.