Guidelines for implementing the Decree amending Decree 132/2020/ND-CP on tax management for enterprises with related-party transactions.

DECREE

AMENDING AND SUPPLEMENTING SOME ARTICLES OF DECREE NO. 132/2020/ND-CP DATED NOVEMBER 5, 2020 OF THE GOVERNMENT REGULATING TAX MANAGEMENT FOR ENTERPRISES WITH RELATED PARTNERSHIP TRANSACTIONS

Based on the Law on Organization of the Government dated June 19, 2015; and the Law amending and supplementing a number of articles of the Law on Organization of the Government and the Law on Organization of Local Government dated November 22, 2019;

Based on the Law on Tax Administration dated June 13, 2019;

Based on the Law on Corporate Income Tax dated June 3, 2008; and the Law amending and supplementing a number of articles of the Law on Corporate Income Tax dated June 19, 2013;

Based on the Law amending and supplementing a number of articles of the Law on Taxation dated November 26, 2014;

At the proposal of the Minister of Finance;

The Government has issued a Decree amending and supplementing a number of articles of Decree No. 132/2020/ND-CP dated November 5, 2020 of the Government regulating tax management for enterprises with related-party transactions.

Article 1. Amending and supplementing a number of articles of Decree No. 132/2020/ND-CP dated November 5, 2020 of the Government regulating tax management for enterprises with related-party transactions.

1. Amend and supplement points d and k, and add point m to clause 2 of Article 5 as follows:

a) Amend and supplement point d as follows:

“d) An enterprise guarantees or lends capital to another enterprise in any form (including third-party loans secured by related-party financing and similar financial transactions) provided that the total outstanding debt of the borrowing enterprise with the lending or guaranteeing enterprise is at least 25% of the owner's equity of the borrowing enterprise and accounts for over 50% of the total outstanding debt of all medium and long-term debts of the borrowing enterprise.

The provisions in point d of this clause do not apply to the following cases:

d.1) The guarantor or lender is an economic organization operating in accordance with the Law on Credit Institutions that does not directly or indirectly participate in the management, control, capital contribution, or investment in the borrowing enterprise or the guaranteed enterprise as stipulated in points a, c, d, e, g, h, k, l, and m of this clause.

d.2) The guarantor or lender is an economic organization operating in accordance with the Law on Credit Institutions, and the borrowing or guaranteed enterprise is not directly or indirectly subject to the same management, control, capital contribution, or investment as another party as stipulated in points b, e, and i of this clause.”

b) Amend and supplement point k as follows:

“k) Other cases in which an enterprise (including independently accounting branches that declare and pay corporate income tax) is subject to the actual management, control, and decision-making power of the other enterprise regarding its business operations;”

c) Add point m as follows:

“m) Credit institutions with their subsidiaries, controlling companies, or affiliated companies as stipulated in the Law on Credit Institutions and its amendments, supplements, or replacements (if any);”

2. Amend and supplement Clause 2 of Article 21 as follows:

2. The State Bank of Vietnam, within the scope of its duties and powers, is responsible for:

Coordinate the provision of information and data on foreign loans and debt repayments of each specific enterprise with related-party transactions, based on the list requested by the Tax Authority, including data on loan amount, interest rate, interest payment period, principal repayment period, actual capital withdrawal, debt repayment (principal and interest), and other relevant information (if any).

"Coordinate the provision of information as required by law regarding related parties of members of the Board of Directors, members of the Board of Members, members of the Supervisory Board, General Director (Director), Deputy General Director (Deputy Director) and equivalent positions as stipulated in the charter of the credit institution; related parties of shareholders owning 01% or more of the charter capital of the credit institution; and affiliated companies of the credit institution, according to the State Bank of Vietnam's management data information system when requested by the tax authorities."

Article 2. Replace Appendix I – Information on related party relationships and related party transactions issued with Government Decree No. 132/2020/ND-CP dated November 5, 2020, regulating tax management for enterprises with related party transactions, with Appendix I issued with this Decree.

Article 3. Transitional provisions

In the case where, during the corporate income tax periods of 2020, 2021, 2022, and 2023, the borrowing enterprise only has an affiliated relationship with an economic organization operating under the provisions of the Law on Credit Institutions as stipulated in point d, clause 2, Article 5 of Decree No. 132/2020/ND-CP, and the borrowing enterprise borrows from a lender or guarantor falling under the cases stipulated in points d.1 and d.2, clause 2, Article 5 of Decree No. 132/2020/ND-CP as amended and supplemented by Article 1 of this Decree, has related-party transactions within the scope of regulation in clause 2, Article 1 of Decree No. 132/2020/ND-CP, and has non-deductible interest expenses as stipulated in point a, clause 3, Article 16 of Decree No. 132/2020/ND-CP, then from the tax period of 2024 onwards, the following shall apply:

1. In cases where a business has no related-party relationships and no related-party transactions as stipulated in Decree No. 132/2020/ND-CP and this Decree, the portion of interest expense that is not deductible and has not been carried forward to subsequent tax periods up to the end of the 2023 tax period shall be evenly allocated to subsequent tax periods for the remaining time, in accordance with the provisions on the period for carrying forward interest expense at point b, clause 3, Article 16 of Decree No. 132/2020/ND-CP.

2. In cases where enterprises have related-party relationships and related-party transactions as stipulated in Decree No. 132/2020/ND-CP and this Decree, interest expenses that are not deductible and cannot be carried forward to subsequent tax periods shall be handled in accordance with the provisions of point b, clause 3, Article 16 of Decree No. 132/2020/ND-CP.

Article 4. Implementation and Effective Date

1. This Decree takes effect from December 27, 2025 and applies from the corporate income tax period of 2024.

2. Ministers, heads of ministerial-level agencies, heads of government agencies, chairpersons of provincial and centrally-administered city People's Committees, and relevant organizations and individuals are responsible for implementing this Decree.

 

Recipients: - Party Central Committee Secretariat; - Prime Minister, Deputy Prime Ministers; - Ministries, ministerial-level agencies and government-attached agencies; - People's Councils, People's Committees of provinces and centrally-run cities; - Central Office and Party Committees; - Office of the General Secretary; - Office of the President; - National Council and Committees of the National Assembly; - Congress office; - Supreme People's Court; - People's Procuratorate of the Supreme; - State audit; - National Financial Supervisory Committee; – Social Policy Bank; - Vietnam Development Bank; – Central Committee of the Vietnam Fatherland Front; - Central agency of unions; - VPCP: Chairman, Deputy Chairmen, TT Assistant, General Director of the Portal, departments, agencies, units, Official Gazette; – Save: VT, KTTH (2).

TM. GOVERMENT Acting Prime Minister DEPUTY PRIME MINISTER Ho Duc Phuoc

 

Appendix I

(Attached to Decree No. 20/2025/ND-CP dated June 10, 2025 of the Government)

INFORMATION REGARDING RELATED PARTNERSHIPS AND RELATED TRANSACTIONS

(Attached is the Corporate Income Tax Return Form)

Tax period: From ………. to ………..

[01] Taxpayer's name ………………………………………………………………………………….

[02] Tax code:

[03] Address: …………………………………………………………………………………………………..

[04] District/County: …………………………… [05] Province/City: ………………………………..

[06] Phone: ………………… [07] Fax: ………………… [08] Email:………………………….

[09] Name of tax agent (if any): …………………………………………………………………………….

[10] Tax code:

SECTION I. INFORMATION ABOUT RELATED PARTIES

STT

Affiliate name

Countries

Tax code

Forms of association[1]

(1)

(2)

(3)

(4)

(5)

A

B

C

D

Đ

E

G

H

I

K

L

M

1

2

3

....

SECTION II. CASES EXEMPT FROM DECLARATION AND FILE PREPARATION OF RELATED PARTY TRANSACTION PRICE DETERMINATION

STT	Exemption cases	Exempt[2]
(1)	(2)	(3)
1	Exempt from declaring transfer pricing under sections III and IV, and exempt from preparing Transfer Pricing Documentation.
	The taxpayer only conducts transactions with related parties that are subject to corporate income tax in Vietnam, applying the same corporate income tax rate as the taxpayer, and neither party is entitled to corporate income tax incentives during the tax period.
2	Exemption from preparing Transfer Pricing Documentation.
a	Taxpayers who have related-party transactions but whose total revenue for the tax period is less than VND 50 billion and whose total value of all related-party transactions during the tax period is less than VND 30 billion
b	Taxpayers who have signed an Advance Pricing Agreement are required to submit annual reports in accordance with the law on Advance Pricing Agreements.
c	Taxpayers engaged in business with simple functions, not generating revenue or expenses from the exploitation or use of intangible assets, and with revenue under 200 billion VND, are subject to the net profit margin before interest and corporate income tax on revenue, including the following sectors:
	– Distribution: 5% or more
	– Production: 10% or more
	– Processing: 15% or more

SECTION III. INFORMATION FOR DETERMINING RELATED PARTY TRANSACTION PRICES

Currency: Vietnamese Dong

STT

Content

Sales value to related parties

Value of purchases from affiliated parties

Profits increased due to revaluation based on independent transaction prices.

Collection and disbursement of funds, allocation of permanent residence facilities.[3]

This transaction falls within the scope of the APA.[4]

The recognized value of related-party transactions

Reassessed value based on independent transaction prices.

Difference

Pricing methods

The recognized value of related-party transactions

Reassessed value based on independent transaction prices.

Difference

Pricing methods

(1)

(2)

(3)

(4)

(5) = (4) - (3)

(6)

(7)

(8)

(9) = (8) - (7)

(10)

(11) = (5) + (9)

(12)

(13)

I

Total value of transactions arising from business operations

II

Total transaction value arising from related party activities

1

Goods

1.1

Goods that constitute fixed assets

a

Affiliate A

b

Affiliate B

...

1.2

Goods that do not constitute fixed assets.

a

Affiliate A

b

Affiliate B

...

2

Services

2.1

Research and development

a

Affiliate A

b

Affiliate B

...

2.2

Advertising, marketing

a

Affiliate A

b

Affiliate B

...

2.3

Business management and consulting, training

a

Affiliate A

b

Affiliate B

...

2.4

Financial activities

2.4.1

Royalties and similar fees

A

Affiliate A

B

Affiliate B

....

2.4.2

Interest

A

Affiliate A

B

Affiliate B

....

2.5

Other services

A

Affiliate A

B

Affiliate B

....

SECTION IV. BUSINESS RESULTS AFTER DETERMINING RELATED PARTY TRANSACTION PRICES

1. For taxpayers in the manufacturing, trade, and service sectors.

The taxpayer has signed an advance pricing agreement (APA).

There is □

No □

Currency: Vietnamese Dong

STT	Targets	Related party transaction value		Transaction value with independent parties	Total value generated from business operations during the period
		Value determined according to the Transfer Pricing Documentation	Value determined according to APA
(1)	(2)	(3)	(4)	(5)	(6) = (3) + (4) + (5)
1	Revenue from sales and service provision
	This includes: Revenue from the sale of exported goods and services.
2	Revenue deductions
3	Net revenue from sales and provision of services (3)=(1)-(2)
XNUMX	Cost of goods sold
5	Gross profit from sales and services (5)=(3)-(4)
6	Cost of sales
7	Enterprise Cost Management
8	Revenue from financial activities
8 1	This includes: Interest on deposits and interest on loans.
9	Financial expenses
9.1	In which: Interest expense
9.1.a	Interest expense is deductible during the period.
9.1.b	The portion of interest expense incurred during the period that is not deductible can be carried forward to the next period as stipulated in point b, clause 3, Article 16.
10	Depreciation expense incurred during the period
11	Net profit from business operations during the period (11)=(5)-(6)-(7)+(8)-(9)
12	Net profit from business operations during the period does not include the difference between revenue and expenses of financial activities (12)=(11)-(8)+(9)
13	Total net profit from business operations plus interest expense after deducting interest on deposits and loans during the period plus depreciation expense during the period (13)=(11)+(9.1)-(8.1)+(10)
14	The ratio of interest expense after deducting interest on deposits and loans incurred during the period to total net profit from business operations plus interest expense after deducting interest on deposits and loans during the period plus depreciation expense during the period (14)=[(9.1)-(8.1)]/(13)
15	Interest expense from previous periods carried forward, in which: (15)=(15.1)+(15.2)+(15.3)+(15.4)+(15.5)
15.1	– The portion of interest expense that is not deductible from year (n-1) is carried over to tax period (n).
15.2	– The portion of interest expense that is not deductible from year (n-2) is carried over to tax period (n).
15.3	– The portion of interest expense that is not deductible from year (n-3) is carried over to tax period (n).
15.4	– The portion of interest expense that is not deductible from year (n-4) is carried over to tax period (n).
15.5	– The portion of interest expense that is not deductible from year (n-5) is carried over to tax period (n).
16	The ratio of interest expense after deducting interest on deposits and loans incurred plus interest expense from previous periods carried over to total net profit from business operations plus interest expense (after deducting interest on deposits and loans) in the period plus depreciation expense in the period (16)=[(9.1)- (8.1)+(15)]/(13)
17	Profit margin used to determine transfer pricing.
17.1	– Rate ………………..
17.2	– Rate ………………..
17.3	– ………………………….

2. For taxpayers in the banking and credit sectors.

The taxpayer has signed an advance pricing agreement (APA).

There is □

No □

Currency: Vietnamese Dong

STT	Targets	Related party transaction value		Transaction value with independent parties	Total value generated from business operations during the period
		Value determined according to the Transfer Pricing Documentation	Value determined according to APA
(1)	(2)	(3)	(4)	(5)	(6) = (3) + (4) + (5)
1	Interest income and similar income
2	Interest expenses and similar costs
3	Net interest income (3)=(1)-(2)
4	Income from service activities
5	Service operation costs
6	Net profit/loss from service activities (6)=(4)-(5)
7	Net profit/loss from foreign exchange trading
8	Net profit/loss from trading securities
9	Net profit/loss from buying and selling investment securities
10	Income from other activities
11	Other operating costs
12	Net profit/loss from other activities (12)=(10)-(11)
13	Income from capital contributions and share purchases.
14	Operating costs
15	Credit risk provisioning costs
16	Total profit before tax (16)=(3)+(6)+(7)+(8)+(9)+ (12)+(13)-(14)-(15)
17	Net profit from business operations (17=16-12)
18	Profit margin used to determine transfer pricing.
18.1	Rate …………….
18.2	Rate …………….
18.3	...........................

3. For taxpayers who are securities companies

The taxpayer has signed an advance pricing agreement (APA).

There is □

No □

Currency: Vietnamese Dong

STT	Targets	Related party transaction value		Transaction value with independent parties	Total value generated from business operations during the period
		Value determined according to the Transfer Pricing Documentation	Value determined according to APA
(1)	(2)	(3)	(4)	(5)	(6) = (3) + (4) + (5)
1	Operating Revenue (1)=(1.1)+(1.2)+(1.3)+(1.4)+(1.5)+(1.6)+(1.7)+(1.8)+(1.9)+ (1.10)+(1.11)
1.1	Profit from financial assets recognized through profit/loss (FVTPL) (1.1)=(1.1.a)+(1.1.b)+(1.1.c)
1.1.a	Profits from the sale of FVTPL financial assets
1.1.b	The difference is increasing in the revaluation of FVTPL financial instruments.
1.1.c	Dividends and interest income arising from FVTPL financial assets.
1.2	Interest from investments held to maturity (HTM)
1.3	Interest from loans and receivables
1.4	Interest from Financial Assets Available for Sale (AFS)
1.5	Profits from hedging derivatives
1.6	Revenue from securities brokerage services
1.7	Revenue from underwriting and securities issuance agency services.
1.8	Revenue from securities investment advisory services
1.9	Revenue from securities custody services
1.10	Revenue from financial advisory services
1.11	Other operating income
2	Operating costs (2)=(2.1)+(2.2)+(2.3)+(2.4)+(2.5)+(2.6)+(2.7)+(2.8)+(2.9)+ (2.10)+(2.11)+(2.12)
2.1	Losses on financial assets recognized through profit/loss (FVTPL) (2.1)=(2.1.a)+(2.1.b)+(2.1.c)
2.1.a	Losses from selling FVTPL financial assets.
2.1.b	The difference decreases as the valuation of FVTPL financial instruments decreases.
2.1.c	Transaction costs for purchasing FVTPL financial assets.
2.2	Losses on investments held to maturity (HTM)
2.3	Losses and differences recognized at fair value of available-for-sale financial assets (AFS) upon reclassification.
2.4	Financial asset provision costs, handling of losses from doubtful receivables and impairment losses on financial assets, and borrowing costs of loans.
2.5	Losses from hedging derivative financial assets
2.6	Proprietary operating expenses
2.7	Securities brokerage fees
2.8	Underwriting and securities issuance agency fees
2.9	Costs of securities investment advisory services
2.10	Securities custody service fees
2.11	Financial advisory service costs
2.12	Costs of other services
3	Financial operating revenue (3)=(3.1)+(3.2)+(3.3)+(3.4)
3.1	Realized and unrealized exchange rate gains
3.2	Revenue, expected dividends, and interest income from bank deposits are not fixed.
3.3	Profits from the sale and liquidation of investments in subsidiaries, associates, and joint ventures.
3.4	Other revenue from investments
XNUMX	Financial costs (4)=(4.1)+(4.2)+(4.3)+(4.4)+(4.5)
4.1	Realized and unrealized exchange rate losses
4.2	Interest expense
4.3	Losses from selling and liquidating investments in subsidiaries, associates, and joint ventures.
4.4	Provision for impairment of long-term financial investments.
4.5	Other financial costs
5	Cost of sales
6	Management costs of securities companies
7	Operation result (7)=(1)-(2)+(3)-(4)-(5)-(6)
8	Total interest earned on deposits and loans during the period.
9	Total interest expense incurred during the period
9.1	Interest expense is deductible during the period.
9.2	The portion of interest expense incurred during the period that is not deductible can be carried forward to the next period as stipulated in point b, clause 3, Article 16.
10	Depreciation expense incurred during the period
11	Total net profit from business operations during the period plus interest expense after deducting interest on deposits and loans incurred during the period plus depreciation expense incurred during the period [(11)=(7)+(9)-(8)+(10)]
12	The ratio of interest expense after deducting interest on deposits and loans incurred during the period to total net profit from business operations plus interest expense after deducting interest on deposits and loans incurred during the period plus depreciation expense incurred during the period (12)=[(9)-(8)]/(11)
13	Interest expense from previous periods carried forward (13)=(13.1)+(13.2)+(13.3)+(13.4)+(13.5) In which:
13.1	– The portion of interest expense that is not deductible from year (n-1) is carried over to tax period (n).
13.2	– The portion of interest expense that is not deductible from year (n-2) is carried over to tax period (n).
13.3	– The portion of interest expense that is not deductible from year (n-3) is carried over to tax period (n).
13.4	– The portion of interest expense that is not deductible from year (n-4) is carried over to tax period (n).
13.5	– The portion of interest expense that is not deductible from year (n-5) is carried over to tax period (n).
14	The ratio of interest expense after deducting interest on deposits and interest on loans incurred in the period plus interest expense from previous periods carried over to the tax period (n) on total net profit from business operations plus net interest expense incurred in the period plus depreciation expense incurred in the period of the taxpayer (14) = [(9)-(8)+(13))/(11)
15	Profit margin used to determine transfer pricing.
15.1	Rate ……………………………
15.2	Rate ……………………………
15.3	.......................................... ..

I certify that the information provided above is accurate and I am legally responsible for the accuracy of this information.

 

TAX AGENT Full name: …………………….. Professional license number: ……

……….., date … month … year…. TAXPAYER or LEGAL REPRESENTATIVE OF THE TAXPAYER (Signature, full name, title, and seal (if any))

 

GUIDELINES FOR DECLARING CERTAIN INDICATORS

A. Tax period: Record the information corresponding to the tax period of the Corporate Income Tax Return. The tax period is determined according to the provisions of the Corporate Income Tax Law.

B. General information of the taxpayer: From item [01] to item [10] record the information corresponding to the information recorded in the Corporate Income Tax Final Settlement Declaration.

C. Section I. Information about affiliated parties:

– Column (2): Fill in the full name of each affiliate:

+ If the affiliated party in Vietnam is an organization, record the information as stated in the business registration certificate; if it is an individual, record the information as stated in their identity card, citizen identification card, or passport.

+ If the related party is an organization or individual outside Vietnam, the information should be recorded according to the document establishing the related party relationship, such as the business registration certificate, contract, or transaction agreement between the taxpayer and the related party.

– Column (3): Record the name of the country or territory where the affiliated party is the resident.

– Column (4): Record the tax code of the affiliated parties:

+ If the affiliated party is an organization or individual in Vietnam, please provide the full tax identification number.

+ If the affiliated party is an organization or individual outside Vietnam, please provide the full tax code and taxpayer identification number; if none are available, please state the reason.

– Column (5): Based on the provisions of Clause 2, Article 5 of Decree No. 132/2020/ND-CP and Article 1 of Decree No. 20/2025/ND-CP, taxpayers who have related party transactions declare the form of related party relationship corresponding to each related party by marking “x” in the corresponding box. In case the related party belongs to more than one form of related party relationship, the taxpayer marks “x” in the corresponding boxes.

D. Section II. Cases exempt from declaring and preparing documentation for determining transfer pricing:

If the taxpayer is exempt from declaring and preparing the Transfer Pricing Documentation as stipulated in Article 19 of Decree No. 132/2020/ND-CP in Column (2), then mark “x” in the corresponding exemption box in Column (3).

In cases where taxpayers are exempt from declaring and preparing transfer pricing documents as prescribed in Clause 1, Article 19 of Decree No. 132/2020/ND-CP, taxpayers only need to mark the corresponding box in Column (3) and do not have to declare items III and IV of Appendix I attached to Decree No. 20/2025/ND-CP.

In cases where taxpayers are exempt from preparing Transfer Pricing Documentation as stipulated in point a or point c, Clause 2, Article 19 of Decree No. 132/2020/ND-CP, taxpayers shall declare items III and IV according to the corresponding instructions in sections D.1 and E.

In cases where taxpayers are exempt from preparing Transfer Pricing Documentation as stipulated in point b, clause 2, Article 19 of Decree No. 132/2020/ND-CP, taxpayers shall declare according to the corresponding instructions in sections D.2 and E.

Section III. Information for determining transfer pricing:

Article 1. In cases where the taxpayer is exempt from preparing a Transfer Pricing Documentation File as stipulated in point a or point c, Clause 2, Article 19 of Decree No. 132/2020/ND-CP and has already marked (x) in column 3 in line a or line c of the exemption from preparing a Transfer Pricing Documentation File in Section II, Appendix I attached to Decree No. 20/2025/ND-CP, this section shall be declared as follows:

– Columns (3), (7) and (12): Fill in as instructed in Section D.2 of this Appendix.

– Columns (4), (5), 6), (8), (9), (10) and (11): Taxpayers leave blank and do not declare.

For cases where taxpayers are exempt from preparing Transfer Pricing Documentation as prescribed in point a, clause 2, Article 19 of Decree No. 132/2020/ND-CP, the total value of all related-party transactions arising in the tax period used as the basis for determining the exemption conditions is calculated by (=) the total value in Column (3) plus (+) Column (7) of the line item “Total value of transactions arising from related-party activities”.

Article 2. Taxpayers who are not exempt from preparing Transfer Pricing Documentation under point a or point c of Clause 2, Article 19 of Decree No. 132/2020/ND-CP shall declare as follows:

– The indicator “Total value of transactions arising from business operations”:

+ Column (3): Record the total sales revenue to affiliated and independent parties, including: Sales revenue and service provision, financial activity revenue and other income (excluding collected amounts).

+ Column (7): Record the total value of expenses payable to related parties and independent parties, including: Costs of purchased goods and services, financial costs, selling costs, business management costs and other costs (excluding expenses paid on behalf of others).

+ Columns (4), (5), (6), (8), (9), (10), (11), (12) and (13): Leave blank, no declaration required.

– Indicator “Total value of transactions arising from related-party activities”:

+ Columns (3), (4), (7) and (8): Record the total value in the corresponding cells for each Goods plus (+) Services indicator.

– The "Goods" indicator:

+ Columns (3), (4), (7) and (8): Record the total value in the corresponding cells for the indicators Goods that form fixed assets plus (+) Goods that do not form fixed assets.

– The item "Goods forming fixed assets" and the detailed lines "Related Party A", "Related Party B",….:

+ Columns (3) and (7): Record the total value arising from the purchase or sale of fixed assets by the taxpayer with related parties according to the value in the accounting books.

+ Columns (4) and (8): Record the total value arising from the purchase or sale of fixed assets with related parties determined according to the corresponding transfer pricing method in Columns (6) and (10).

– The item "Goods not forming fixed assets" and the detailed lines "Related Party A", "Related Party B",….:

+ Columns (3) and (7): Record the total value arising from the purchase or sale of goods that are not fixed assets of the taxpayer with related parties according to the value in the accounting books.

+ Columns (4) and (8): Record the total value arising from the purchase or sale of goods that are not fixed assets of the taxpayer with related parties determined according to the corresponding transfer pricing method in Columns (6) and (10).

– The "Service" indicator:

+ Columns (3), (4), (7) and (8): Record the total value in the corresponding cells for the indicators “Research and development” plus (+) “Advertising and marketing” plus (+) “Business management and consulting, training” plus (+) “Financial activities plus” (+) “Other services”.

– The indicators include “Research and Development”; “Advertising and Marketing”; “Business Management and Consulting, Training”; “Financial Activities and Other Services”, and details for each “Affiliated Party A”, “Affiliated Party B”,…:

+ Columns (3) and (7): Record the total value of each type of service arising from transactions with related parties recorded at the value recorded in the accounting books.

+ Columns (4) and (8): Record the total value of each type of service arising from transactions with related parties determined according to the corresponding transfer pricing method in Column (6) and Column (10).

– Columns (6) and (10): Record the abbreviation of the method for determining transfer pricing for each related party as prescribed in Articles 13, 14, and 15 of Decree No. 132/2020/ND-CP, which constitutes the value of sales to related parties and the value of purchases from related parties of the taxpayer determined according to the Transfer Pricing Documentation, specifically as follows:

+ PP1: Method of comparing related-party transaction prices with independent transaction prices (independent transaction price comparison method).

+ PP2: Method of comparing the taxpayer's profit margin with the profit margin of independent comparable entities.

PP2-1: Method of comparing gross profit margin on revenue (resale price method).

PP2-2: Method of comparing gross profit margin on cost of goods sold (cost-plus profit method).

PP2-3: Method for comparing net profit margins.

+ PP3: Method of profit distribution among affiliated parties.

For example:

+ Purchase machinery from affiliated party A based on the independent transaction price comparison method, in the line item Goods forming fixed assets from affiliated party A Column (10): Record PP1.

+ Collect management service fees provided to affiliated party B based on the cost plus profit method, in the line item Business management and consulting, training for affiliated party B Column (6): Record PP2-2.

– Columns (5) and (9): Record the total value determined according to the calculation formula in Appendix I issued with Decree No. 20/2025/ND-CP.

– Column (11): Record the profit increase due to reassessment based on independent transaction prices.

– Column (12): Record in order the total value of collected payments, the total value of disbursed payments, the total value of revenue allocated to the permanent establishment, and the total value of expenses allocated to the permanent establishment incurred during the tax period.

– Column (13): Fill in according to the instructions in Appendix I issued with Decree No. 20/2025/ND-CP corresponding to each transaction within the scope of APA application and leave blank the boxes corresponding to the lines of indicators recording the total value.

E. Section IV. Business results after determining transfer pricing:

– The indicator “Taxpayers who have signed an advance pricing agreement (APA)”:

Taxpayers should mark “x” in “Yes” if they have signed a unilateral, bilateral or multilateral APA with the Vietnamese Tax Authority. If the taxpayer has not signed an APA with the Tax Authority, they should mark “x” in “No” and leave blank the indicators in Column (4) of the business results table in this section.

– Taxpayers who only generate income or revenue with independent parties shall declare in Column (6) of the business results table in accordance with each type of enterprise for each corresponding indicator as guided in this Appendix.

1. For taxpayers in the manufacturing, trade, and service sectors:

a) In cases where the taxpayer has already marked (x) in Column 3, line 2a, exempting them from preparing the Transfer Pricing Documentation under Section II, Appendix I of Decree No. 20/2025/ND-CP, they should declare according to the following instructions:

– The criteria in lines (1), (2), (3), (4), (5), (6), (7), (8), (8.1), (9), (9.1), (9.1.a), (9.1.b), (10), (11) and (12):

+ Columns (3), (4) and (5): Taxpayers leave blank and do not declare.

+ Column (6): Record the value determined from the data in the Financial Statement.

– The indicators in lines (13), (14), (15), (15.1), (15.2), (15.3), (15.4), (15.5) and (16) are determined and calculated according to the provisions of point a, point b, clause 3, Article 16 of Decree No. 132/2020/ND-CP.

– Item in line (17): Taxpayer leaves blank and does not declare.

b) In cases where the taxpayer has already marked (x) in Column 3, line 2c, exempting them from preparing a Transfer Pricing Documentation File under Section II, Appendix I of Decree No. 20/2025/ND-CP, they should declare according to the following instructions:

– The criteria in lines (1), (2), (3), (4), (5), (6), (7), (8), (8.1), (9), (9.1), (9.1.a), (9.1.b), (10), (11) and (12):

+ Columns (3), (4) and (5): Taxpayers leave blank and do not declare.

+ Column (6): Record the value determined from the data in the Financial Statement.

– The indicators in lines (13), (14), (15), (15.1), (15.2), (15.3), (15.4), (15.5) and (16) are determined and calculated according to the provisions of point a, point b, clause 3, Article 16 of Decree No. 132/2020/ND-CP.

– The indicator “Rate of profit used to determine transfer pricing”

+ Column (2): Record the net profit margins from production and business activities in the period excluding the difference between revenue and expenses of financial activities on net revenue in the indicator lines (17.1), (17.2), (17.3), (17…) as prescribed in point c, clause 2, Article 19 of Decree No. 132/2020/ND-CP.

+ Columns (3), (4) and (5): Taxpayers leave blank and do not declare.

+ Column 6: Taxpayers declare the value of net profit from business operations during the period, excluding the difference between revenue and expenses of financial activities and net revenue, for the business sector as stipulated in point c, clause 2, Article 19 of Decree No. 132/2020/ND-CP.

In cases where a taxpayer conducts business in more than one field, they must separately track and account for the revenue and expenses of each field, or they can separately track and account for revenue but not the expenses incurred by each field, and must file separate tax returns for each field.

In cases where a taxpayer conducts business in more than one field and cannot separately track and account for the revenue and expenses of each field, they must declare their income and expenses based on the field with the highest profit margin.

c) In cases where the taxpayer is not exempt from preparing the Transfer Pricing Documentation as stipulated in point a or point c, Clause 2, Article 19 of Decree No. 132/2020/ND-CP, the declaration shall be as follows:

– The target for “Revenue from sales and services”:

+ Columns (3) and (4): Record the total value of transactions supplying goods and services to related parties, determining the price according to the Related Party Pricing Documentation in Column (3) and according to the APA in Column (4).

+ Column (5): Record the total value of transactions providing goods and services to independent parties according to the value recorded in the accounting books.

+ Column (6): Record the total value determined according to the calculation formula in Appendix I issued with Decree No. 20/2025/ND-CP.

For the indicators “Revenue from the sale of goods and services for export” and “Revenue deductions”: Taxpayers declare the corresponding revenue from the sale of goods and provision of services and record it according to the same instructions in the “Revenue from the sale of goods and provision of services” indicator.

– The target for “Net revenue from sales and services”:

+ Columns (3), (4), (5) and (6): Record the value equal to the corresponding value in each column at the indicator “Sales revenue and service provision” minus (-) the indicator “Revenue deductions”.

– The "Cost of Goods Sold" indicator:

+ Columns (3) and (4): Record the total value of the cost of goods sold corresponding to the revenue from sales and provision of services to related parties and equals (=) the total value arising with related parties determined according to the Transfer Pricing Documentation and according to APA plus (+) the value of transactions arising with independent parties recorded in the accounting books.

+ Column (5): Record the total value of cost of goods sold corresponding to sales revenue and provision of services to independent parties and equals (=) the total value arising with related parties determined according to the Transfer Pricing Documentation and according to APA plus (+) the value of transactions arising with independent parties recorded in the accounting books.

+ Column (6): Record the total value determined according to the calculation formula in Appendix I issued with Decree No. 20/2025/ND-CP.

– The indicator “Gross profit from sales and services”:

+ Columns (3), (4), (5) and (6) have the value equal to the corresponding value in each column of the indicator “Net revenue from sales and provision of services” minus (-) the indicator “Cost of goods sold”.

– The indicators for “Selling expenses” and “Administrative expenses”:

+ Columns (3) and (4): Record the total value of selling expenses and business management expenses corresponding to sales revenue and services provided to related parties equal to (=) the total value incurred with related parties determined according to the Transfer Pricing Documentation and according to APA plus (+) the value of transactions incurred with independent parties recorded in the accounting books.

+ Column (5): Record the total value of selling expenses and business management expenses corresponding to sales revenue and provision of services to independent parties equal to (=) the total value incurred with related parties determined according to the Transfer Pricing Documentation and according to APA plus (+) the value of transactions incurred with independent parties recorded in the accounting books.

+ Column (6): Record the total value determined according to the calculation formula in Appendix I issued with Decree No. 20/2025/ND-CP.

– For cost indicators arising in production and business activities, taxpayers shall monitor accounting and record the accounting value, separately determining costs from related parties within the scope of price determination according to the Transfer Pricing Documentation; according to APA and transactions with independent parties corresponding to columns (3), (4) and (5). If it is not possible to determine separately, the taxpayer shall choose the most appropriate allocation criterion according to one or more factors such as revenue, costs, assets, human resources or other factors consistent with the nature of the activity and record the allocated cost value in the corresponding cells (3), (4) and (5).

– The indicator “Financial operating revenue”:

+ Columns (3), (4) and (5): Taxpayers leave blank and do not declare.

+ Column (6): Record the total value of financial activity revenue.

– The "Interest on deposits and loans" item: Records the value of interest earned from lending activities and includes it in financial income for the period.

+ Columns (3), (4) and (5): Taxpayers leave blank and do not declare.

+ Column (6): Record the total value as determined in the Transfer Pricing Documentation, according to APA for transactions arising with related parties and the value recorded in the accounting books for transactions arising with independent parties.

– The "Financial Costs" indicator:

+ Columns (3), (4) and (5): Taxpayers leave blank and do not declare.

+ Column (6): Record the total value of financial operating expenses.

– The item “Interest expense on loans used for production and business activities”: Record the value of interest expense included in financial expenses for the period.

+ Columns (3), (4) and (5): Taxpayers leave blank and do not declare.

+ Column (6): Record the total value as determined in the Transfer Pricing Documentation, according to APA for transactions arising with related parties and the value recorded in the accounting books for transactions arising with independent parties.

– The indicator “Depreciation expense incurred during the period”:

+ Columns (3), (4) and (5): Taxpayers leave blank and do not declare.

+ Column (6): Record the total value of depreciation expense included in the expenses during the period and is determined by the total value of depreciation expense included in the cost of goods sold, selling expenses and business management expenses.

– The indicator “Net profit from business operations during the period”:

+ Columns (3), (4) and (5): Taxpayers leave blank and do not declare.

+ Column (6): Record the value equal to the corresponding value in each column at the indicator “Gross profit from sales and services” minus (-) the indicator “Selling expenses” minus (-) the indicator “Business management expenses” plus (+) the indicator “Financial revenue” minus (-) the indicator “Financial expenses”.

– The indicator “Net profit from business operations during the period, excluding the difference between revenue and expenses of financial activities”:

+ Columns (3), (4), (5) and (6): Record the value equal to the corresponding value in each column at the indicator “Gross profit from sales and services” minus (-) the indicator “Selling expenses” minus (-) the indicator “Business management expenses”.

– The indicator “Total net profit from business operations plus interest expense after deducting interest on deposits and loans during the period plus depreciation expense during the period”:

+ Columns (3), (4) and (5): Taxpayers leave blank and do not declare.

+ Column (6): Record the value equal to the value of the indicator “Net profit from production and business activities” plus (+) the indicator “Interest expense” minus (-) the indicator “Interest on deposits and loans” plus (+) the indicator “Depreciation expense”.

– The indicator “Ratio of interest expense after deducting interest on deposits and loans incurred during the period to total net profit from business operations plus interest expense after deducting interest on deposits and loans during the period plus depreciation expense during the period”:

+ Columns (3), (4) and (5): Taxpayers leave blank and do not declare.

+ Column (6): Record the percentage value equal to (=) the value [indicator “Interest expense on loans” minus (-) indicator “Interest on deposits and loans”] divided (:) by the value of indicator “Total net profit from business operations plus interest expense after deducting interest on deposits and loans in the period plus depreciation expense in the period”.

– The indicator “Profit margin used to determine transfer pricing”:

+ Column (2): Record the profit margins applied to adjust and determine the transfer pricing in the indicator lines (17.1), (17.2), (17.3),… corresponding to the transfer pricing determination method as prescribed in Articles 13, 14, and 15 of Decree No. 132/2020/ND-CP.

+ Columns (3) and (4): Record the profit margin value used to determine the transfer pricing according to the Transfer Pricing Documentation in Column (3) and according to the APA in Column (4).

+ Columns (5) and (6): Taxpayers leave blank and do not declare.

For example:

+ Taxpayers using the net profit margin comparison method and applying Net profit from business operations in the period excluding the difference between revenue and expenses of financial activities and total expenses to determine net profit in the tax period, in Column (2) item (17.1): Record Net profit from business operations in the period excluding the difference between revenue and expenses of financial activities and total expenses and declare the corresponding rate according to the Transfer Pricing Documentation in Column (3) and according to APA in Column (4).

+ Taxpayers using the comparative method of net profit margin and applying Net profit from business operations in the period excluding the difference between revenue and expenses of financial activities and total expenses for production activities according to the Transfer Pricing Documentation; Net profit from business operations in the period excluding the difference between revenue and expenses of financial activities and net revenue for distribution activities according to APA, in Column (2) indicators (17.1) and (17.2): Record Net profit from business operations in the period excluding the difference between revenue and expenses of financial activities and total expenses for production activities in indicator (17.1) and declare the corresponding ratio in Column (3); record Net profit from business operations in the period excluding the difference between revenue and expenses of financial activities and net revenue for distribution activities in indicator (17.2) and declare the corresponding ratio in Column (4).

– In cases where a taxpayer performs multiple production and business functions and uses different profit margins to determine transfer pricing, the results of production and business activities must be declared separately for each production and business function after determining the transfer pricing.

2. For taxpayers in the banking and credit sectors:

– Indicator “Interest income and similar income”:

+ Columns (3), (4) and (5): Record the total value of interest income and similar income from related parties not signing the APA determined according to the Transfer Pricing Documentation in Column (3), according to the APA in Column (4) and according to the book value arising with the independent party in Column (5).

+ Column (6): Record the total value determined according to the calculation formula in Appendix I issued with Decree No. 20/2025/ND-CP.

– The item "Interest expense and similar expenses":

+ Columns (3) and (4): Record the total value of Interest Payments and similar expenses corresponding to Interest Income and similar income received from related parties and equals (=) the total value arising with related parties determined according to the Transfer Pricing Documentation and according to the APA plus (+) the value of transactions arising with independent parties recorded in the accounting books.

+ Column (5): Record the total value of Interest payments and similar expenses corresponding to Interest income and similar income received from independent parties equal to (=) the total value arising with related parties determined according to the Transfer Pricing Documentation and according to APA plus (+) the value of transactions arising with independent parties recorded in the accounting books.

+ Column (6): Record the total value determined according to the calculation formula in Appendix I issued with Decree No. 20/2025/ND-CP.

– The indicator “Net interest income”:

Columns (3), (4), (5) and (6): Record the value equal to (=) the corresponding value in each column at the indicator Interest income and similar income minus (-) the indicator Interest payments and similar expenses.

– For the item “Income from service activities”: Fill in according to the same instructions as for the item Interest income and similar income.

– For the "Service Operating Expenses" item: Record according to the same instructions as for the "Interest Payments and Similar Expenses" item.

– The indicator “Net profit/loss from service operations”:

Columns (3), (4), (5) and (6): Record the value equal to (=) the corresponding value in each column at the indicator “Income from service activities” minus (-) the indicator “Service activity expenses”.

– The indicators “Net profit/loss from foreign exchange trading”, “Net profit/loss from trading securities”, “Net profit/loss from investment securities”: Record according to the same instructions as for the indicator “Interest income and similar income”.

– For the item “Income from other activities”: Fill in according to the same instructions as for the item “Interest income and similar income”.

– For the item “Other operating expenses”: Record according to the same instructions as for the item Interest payments and similar expenses.

– Indicator “Net profit/loss from other activities”:

Columns (3), (4), (5) and (6): Record the value equal to (=) the corresponding value in each column at the indicator “Income from other activities” minus (-) the indicator “Other operating expenses”.

– For the item “Income from capital contributions and share purchases”: Record according to the same instructions as for the item “Interest income and similar income”.

– For the "Operating Expenses" item: Record according to the same instructions as for the "Interest Payments and Similar Expenses" item.

– The indicator “Credit risk provision expenses”:

+ Columns (3), (4) and (5): Record the total value of credit risk provision costs corresponding to income and revenue-related items in Columns (3), (4) and (5) that are provisioned.

+ Column (6): Record the total value determined according to the calculation formula in Appendix I issued with Decree No. 20/2025/ND-CP.

– For expenses incurred in business operations, taxpayers account for and determine separately each revenue item in columns (3), (4), (5) and record the separately accounted and determined value. If it is not possible to determine separately, the taxpayer chooses the most appropriate allocation method according to one or more factors such as revenue, expenses, assets, human resources or other factors suitable to the nature of the operation and record the allocated expense value in the corresponding cells (3), (4) and (5).

– The indicator “Total profit before tax”: Reflects the total profit realized before tax by the banking and credit institution during the tax period and is determined as follows:

+ Columns (3), (4), (5) and (6): Record the value equal to (=) the corresponding value in each column at the indicator “Net interest income” plus (+) the indicator “Net profit/loss from service activities” plus (+) the indicator “Net profit/loss from foreign exchange trading activities” plus (+) the indicator “Net profit/loss from trading securities” plus (+) the indicator “Net profit/loss from investment securities” plus (+) the indicator “Net profit/loss from other activities” plus (+) the indicator “Income from capital contributions, share purchases” minus (-) the indicator “Operating expenses” minus (-) the indicator “Credit risk provision expenses”.

– Target: “Net profit from business operations”:

+ Columns (3), (4), (5) and (6): Record the value equal to the corresponding value in each column at the indicator “Total profit before tax” minus (-) the indicator “Net profit/loss from other activities”.

– The indicator “Profit margin used to determine transfer pricing”:

+ Column (2): Record the profit margins applied to adjust and determine the transfer pricing in the indicator lines (18.1), (18.2), (18.3) ... corresponding to the transfer pricing determination method as prescribed in Articles 13, 14, and 15 of Decree No. 132/2020/ND-CP.

+ Columns (3) and (4): Record the profit margin value applied to determine the transfer pricing according to the Transfer Pricing Documentation in Column (3) and according to the APA in Column (4).

+ Columns (5) and (6): Taxpayers leave blank and do not declare.

3. For taxpayers who are securities companies:

a) If the taxpayer has already marked (x) in Column 3, line 2a, Section II, Appendix I attached to Decree No. 20/2025/ND-CP, proceed with the declaration as follows:

– The criteria in lines (1.1.a), (1.1.b), (1.1.c), (1.2), (1.3), (1.4), (1.5), (1.6), (1.7), (1.8), (1.9), (1.10), (1.11), (2.1.a), (2.1.b), (2.1.c), (2.2), (2.3), (2.4), (2.5), (2.6), (2.7), (2.8), (2.9), (2.10), (2.11), (2.12), (3.1), (3.2), (3.3), (3.4), (4.1), (4.2), (4.3), (4.4), (4.5), (5), (6), (7), and (10):

+ Columns (3), (4) and (5): Taxpayers leave blank and do not declare.

+ Column (6): Record the value determined from the data in the Financial Statement.

– Item in line (15): Taxpayer leaves blank and does not declare.

b) In cases where the taxpayer is not exempt from preparing the Transfer Pricing Documentation as stipulated in point a, clause 2, Article 19 of Decree No. 132/2020/ND-CP, the declaration should be as follows:

– The criteria in lines (1.1.a), (1.1.b), (1.1.c), (1.2), (1.3), (1.4), (1.5), (1.6), (1.7), (1.8), (1.9), (1.10), (1.11), (2.1.a), (2.1.b), (2.1.c), (2.2), (2.3), (2.4), (2.5), (2.6), (2.7), (2.8), (2.9), (2.10), (2.11), (2.12), (3.1), (3.2), (3.3), (3.4), (4.1), (4.2), (4.3), (4.4), (4.5), (5), (6) and (10):

+ Columns (3), (4) and (5): Record the total value of interest income and similar income from related parties not signing the APA determined according to the Transfer Pricing Documentation in Column (3), according to the APA in Column (4) and according to the book value arising with the independent party in Column (5).

+ Column (6): Record the total value determined according to the calculation formula in Appendix I issued with Decree No. 20/2025/ND-CP.

– For expense items incurred during the period, taxpayers shall monitor accounting and record the accounting value, separately determining expenses from related parties within the scope of price determination according to the Transfer Pricing Documentation; according to APA and transactions with independent parties corresponding to columns (3), (4) and (5). If separate determination is not possible, the taxpayer shall choose the most appropriate allocation criterion according to one or more factors such as revenue, expenses, assets, human resources or other factors consistent with the nature of the activity and record the allocated expense value in the corresponding cells (3), (4) and (5).

– The indicator “Total net profit from business operations during the period plus interest expense after deducting interest on deposits and loans incurred during the period plus depreciation expense incurred during the period”:

+ Columns (3), (4) and (5): Taxpayers leave blank and do not declare.

+ Column (6): Record the value equal to the value of the indicator “Operating results” plus (+) the indicator “Total interest expense incurred during the period” minus (-) “Total interest on deposits and loans incurred during the period” plus (+) the indicator “Depreciation expense incurred during the period”.

– The indicator “Ratio of interest expense after deducting interest on deposits and loans incurred during the period to total net profit from business operations plus interest expense after deducting interest on deposits and loans incurred during the period plus depreciation expense incurred during the period”:

+ Columns (3), (4) and (5): Taxpayers leave blank and do not declare.

+ Column (6): Record the percentage value equal to (=) the value (indicator “Total Interest Expense on Loans” minus (-) indicator “Total Interest on Deposits and Loans”] divided (:) by the value of indicator “Net Profit from Business Operations plus Interest Expense plus Depreciation Expense incurred during the period”.

– The indicator “Profit margin used to determine transfer pricing”:

+ Column (2): Record the profit margins applied to adjust and determine the transfer pricing in the indicator lines (15.1), (15.2), (15.3), ... corresponding to the transfer pricing determination method as prescribed in Clauses 2 and 3 of Article 13, Article 14, and Article 15 of Decree No. 132/2020/ND-CP.

+ Columns (3) and (4): Record the profit margin value applied to determine the transfer pricing according to the Transfer Pricing Documentation in Column (3) and according to the APA in Column (4).

+ Columns (5) and (6): Taxpayers leave blank and do not declare.

 

[1] Taxpayers mark “x” in the column of related party relationship declared according to the provisions of Clause 2, Article 5 of Government Decree No. 132/2020/ND-CP dated November 5, 2020 and Article 1 of Government Decree No. 20/2025/ND-CP dated February 10, 2025. In case the related party belongs to more than one related party relationship form, the taxpayer marks “x” in the corresponding boxes.

[2] Taxpayers mark “x” in the line corresponding to the applicable exemption.

[3] The value allocated to the permanent establishment must be declared and clearly noted as whether it is an allocation of revenue or expenses to the permanent establishment.

[4] Taxpayers declare “x” for transactions within the scope of APA and “no” for transactions outside the scope of APA.