The short answer Under Vietnam’s transfer pricing framework, two parties are generally treated as related if one directly or indirectly holds 25% or more of the other’s charter capital, if both are controlled by a common third party holding 25% or more, if one guarantees 25% or more of the other’s borrowings, if one has the right to appoint a majority of the other’s board, or if a single individual holds 25% or more in both entities. Transactions between a company and its per

The short answer Vietnam applies withholding tax mainly through the Foreign Contractor Tax (FCT) regime — a combined VAT and corporate income tax withheld on payments to foreign entities without a Vietnamese legal presence — plus separate rules for dividends, interest, and personal income tax withholding on payments to individuals. There is no single flat “withholding tax rate”: the rate depends on the nature of the payment (goods, services, royalties, interest, dividends) an

The short answer There is currently no double taxation agreement (DTA) in force between the United States and Vietnam. A treaty — the Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — was signed by both governments in 2015 and ratified on the Vietnamese side in 2017. It has never been ratified by the US Senate, and provisions in the text that fell out of step with US tax law changes after 2020 have kept it in

The short answer Expats in Vietnam are taxed based on residency status, not nationality or visa type. Tax residents (present 183+ days in a calendar year or 12 consecutive months, or maintaining permanent accommodation in Vietnam) are taxed on worldwide income at progressive rates now running from 5% to 35% across five brackets under Vietnam’s new Personal Income Tax Law (Law No. 109/2025/QH15), effective from 1 July 2026 with employment and business income provisions applyin

The short answer As of 1 July 2026, Vietnam’s transfer pricing regime is governed by Decree No. 255/2026/ND-CP, which repealed and replaced the previous framework under Decree 132/2020/ND-CP and Decree 20/2025/ND-CP. The new decree applies from the 2026 corporate income tax year and largely retains Vietnam’s existing arm’s-length framework while updating related-party definitions, documentation exemptions, data sources for benchmarking, and Country-by-Country Reporting obliga

The short answer Vietnam’s Personal Income Tax Law No. 109/2025/QH15 took effect on 1 July 2026, replacing the 2007 PIT Law framework, alongside implementing Decree No. 253/2026/ND-CP and Ministry of Finance Circular No. 87/2026/TT-BTC. Provisions governing business income and employment income for resident individuals apply from the 2026 tax year. The headline changes: PIT brackets simplified from seven to five (rates 5%–35%), higher personal and dependent deductions, expand

The short answer Vietnam has signed Double Tax Agreements (DTAs) with approximately 80 countries and territories, based largely on the OECD model treaty, to prevent the same income being taxed twice and to allocate taxing rights between Vietnam and the treaty partner. DTAs apply to residents of Vietnam, the treaty partner, or both, and typically cover income tax, reduced withholding rates on dividends, interest and royalties, and relief mechanisms such as foreign tax credits

Decree No. 337/2025/ND-CP (“Decree 337/2025”) and Circular 08/2026/TT-BNV (“Circular 08/2026”) governing Electronic Labor Contracts (“eLC”) have recently been issued, marking an important step in completing the legal framework for entering into and performing labor contracts in the digital environment. As enterprises increasingly apply technology to human-resource management, understanding the new regulations on eLCs is necessary to ensure legal compliance and to limit legal

On 1 July 2026, the Ministry of Finance issued Circular No. 95/2026/TT-BTC, providing new guidance on the implementation of Double Taxation Agreements between Vietnam and other countries and territories, together with guidance on Mutual Agreement Procedures and Advance Pricing Agreements applicable to enterprises engaging in related-party transactions. The new guidance took effect on 1 July 2026 and introduces several significant developments concerning treaty entitlement, be

On 30 June 2026, the Government issued Decree No. 253/2026/ND-CP prescribing detailed provisions and measures for the implementation of the Law on Personal Income Tax ("PIT"). In addition to the contents covered in our previous newsletter on the new Law on PIT, below are certain notable points for enterprises, employers, and employees. Please refer to our previous newsletter on the new Law on PIT at this link: W&A_Newsletter on the Law on Personal Income Tax The key highlight

Over the past period, Vietnam Customs has issued various directives, plans and official letters guiding customs inspection and supervision of origin, goods labelling and prevention of illegal transshipment in respect of imported, exported and transited goods. Regional Customs Sub-Departments have also proactively developed action plans, assigned responsibilities and implemented inspection measures at border-gate and off-border-gate customs units. These efforts have helped det