TAX ALERT - KEY UPDATES ON TAX AGREEMENT, APA & MAP

On 1 July 2026, the Ministry of Finance issued Circular No. 95/2026/TT-BTC (“Circular 95”), which took effect on the same date, consolidating and providing guidance on the implementation of regulations regarding Double Taxation Agreements (“DTA”), Mutual Agreement Procedure (“MAP”), and Advance Pricing Agreement (“APA”) mechanisms applicable to enterprises with related-party transactions. Circular 95 is expected to establish a unified legal framework, clarify the procedures for applying tax treaty benefits, resolving international tax disputes, and implementing the APA mechanism. This will support enterprises in enhancing tax certainty in cross-border transactions and transfer pricing activities.