TRANSFER PRICING OVER DIFFERENT TIME PERIODS AND SUMMARY REGARDING THE CONDITIONS FOR BEING EXEMPTED FROM TPD

– Circular No. 117/2005/TT-BTC: applicable from 2005 to 2009:

Companies are obliged to prepare and retain records including information, documents and invoices detailing related party transactions.

– Circular No. 66/2010/TT-BTC: applicable from 2010 to 2016:

Companies are obliged to prepare and retain records including information, documents and invoices detailing related party transactions.

– Decree No. 20/2017/ND-CP: applicable from 2017 to 2019:

Companies are exempted from preparing documents to determine the prices of related-party transactions in the following cases: The tax-paying entity incurs a related-party transaction but the total revenue generated in the tax period is less than 50 billion VND and the total value of all related-party transactions arising during the tax period are less than 30 billion VND.

– Decree No. 132/2020/ND-CP: applicable from 2020:

Companies are exempted from preparing documents to determine the prices of related-party transactions in the following cases: The tax-paying entity incurs a related-party transaction but the total revenue generated in the tax period is less than 50 billion VND and the total value of all related-party transactions arising during the tax period are less than 30 billion VND.