Guidance on the implementation of the Decree amending Decree 132/2020/ND-CP on tax management for enterprises with related-party transactions

DECREE

AMENDING AND SUPPLEMENTING A NUMBER OF ARTICLES OF DECREE NO. 132/2020/ND-CP DATED NOVEMBER 05, 11 OF THE GOVERNMENT REGULATIONS ON TAX MANAGEMENT FOR ENTERPRISES WITH ASSOCIATED TRANSACTIONS

Pursuant to the June 19, 6 Law on Government Organization; The Law amending and supplementing a number of articles of the Law on Government Organization and the Law on Organization of Local Government dated November 2015, 22;

Pursuant to the Law on Tax Administration dated June 13, 6;

Pursuant to the June 03, 6 Law on Corporate Income Tax; Law amending and supplementing a number of articles of the Law on Corporate Income Tax dated June 2008, 19;

Pursuant to the Law amending and supplementing a number of articles of the Law on Tax dated November 26, 11;

At the proposal of the Minister of Finance;

The Government issued a Decree amending and supplementing a number of articles of Decree No. 132/2020/ND-CP dated November 05, 11 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 05, 11 of the Government regulating tax management for enterprises with related party transactions

1. Amend and supplement points d, k and add point m, clause 2, 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 loans from third parties secured by the financial resources of the affiliated party and financial transactions of a similar nature) provided that the total outstanding loans of the borrowing enterprise with the lending or guarantor enterprise is at least equal to 25% of the equity capital of the borrowing enterprise and accounts for more than 50% of the total outstanding loans 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 under the provisions of 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 prescribed 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 under the provisions of the Law on Credit Institutions and the borrowing or guaranteed enterprise is not directly or indirectly subject to the management, control, capital contribution or investment of another party as prescribed 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 an independent accounting branch that declares and pays corporate income tax) is subject to the actual management, control, and decision-making on the production and business activities of the other enterprise;”

c) Add point m as follows:

“m) Credit institutions with Subsidiaries or with Controlling Companies or with Affiliates of credit institutions as prescribed in the Law on Credit Institutions and amendments, supplements or replacements (if any);”

2. To amend and supplement Clause 2, Article 21 as follows:

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

Coordinate in providing information and data on foreign loans and repayments of each specific enterprise having associated transactions on the basis of a list requested by the tax authority, including data on loan turnover. , interest rate, interest payment period, principal payment, actual withdrawal, debt repayment (principal, interest) and other relevant information (if any).

Coordinate the provision of information reported in accordance with legal regulations on related persons 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 prescribed in the Charter of the credit institution; related persons of shareholders owning 01% or more of the charter capital of the credit institution; affiliated companies of the credit institution according to the management data information system of the State Bank when requested by the tax authority.”

Article 2. Replace Appendix I - Information on related-party relationships and related-party transactions issued together with Decree No. 132/2020/ND-CP dated November 05, 11 of the Government regulating tax management for enterprises with related-party transactions with Appendix I issued together with this Decree.

Article 3. Transitional provisions

In the case that, in the corporate income tax calculation 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 prescribed in Point d, Clause 2, Article 5 of Decree No. 132/2020/ND-CP and the borrowing enterprise with the lender or guarantor falls under the cases prescribed in Point d.1 and Point d.2, Clause 2, Article 5 of Decree No. 132/2020/ND-CP as amended and supplemented in 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 prescribed in Point a, Clause 3, Article 16 of Decree No. 132/2020/ND-CP, then from the tax calculation period of 2024, the following shall apply: after:

1. In case an enterprise has no related-party relationship and does not have related-party transactions as prescribed in Decree No. 132/2020/ND-CP and this Decree, the non-deductible interest expense that has not been transferred to the following tax periods up to the end of the 2023 tax period shall be evenly distributed to the following tax periods for the remaining period according to the provisions on the time for transferring interest expense at Point b, Clause 3, Article 16 of Decree No. 132/2020/ND-CP.

2. In case an enterprise has an affiliated relationship and related-party transactions as prescribed in Decree No. 132/2020/ND-CP and this Decree, the interest expense is not deductible and has not been transferred to the next tax periods in accordance with the provisions at Point b, Clause 3, Article 16 of Decree No. 132/2020/ND-CP.

Article 4. Implementation organization and implementation effect

1. This Decree takes effect from December 27, 3 and applies from the corporate income tax period 2025.

2. Ministers, Heads of ministerial-level agencies, Heads of Government agencies, Chairmen of People's Committees of provinces and centrally run cities 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; – Bank for Social Policy; - Vietnam Development Bank; - Vietnam Fatherland Front Central Committee; - 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 KT. PRIME MINISTER VICE PRIME MINISTER Ho Duc Phuc

 

Appendix I

(Attached to the Decree No. XNXX / 20 / ND-CP dated 2025 month 10X year 02 of the Government)

INFORMATION ABOUT LINK RELATIONS AND LINKS TRANSACTIONS

(Attached to the corporate income tax finalization declaration)

Tax period: From ………. to ………..

[01] Taxpayer name ………………………………………………………………………………….

[02] Tax code:

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

[04] District: …………………………… [05] Province/city: ………………………………..

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

[09] Tax agent name (if any): …………………………………………………………………………….

[10] Tax code:

SECTION I. INFORMATION ABOUT THE PARTIES

STT

Name of the affiliate

Countries

Tax code

Affiliate relationship form[1]

(1)

(2)

(3)

(4)

(5)

A

B

C

D

Đ

E

G

H

I

K

L

M

1

2

3

....

SECTION II. CASE OF BENEFITS OF DECLARATION AND EXemption from Documenting ASSOCIATION OF LINK TRANSACTION PRICES

STT	Exemption case	Subject to exemption[2]
(1)	(2)	(3)
1	Exemption from declaration and determination of transfer pricing prices in Sections III and IV and exemption from preparation of transfer pricing documents
	Taxpayers only make transactions with affiliated parties that pay corporate income tax in Vietnam, apply the same corporate income tax rate to taxpayers and neither party is entitled to tax incentives Enterprise income in taxation period
2	No fee for setting up the linked transaction price determination file
a	Taxpayers have associated transactions but the total revenue generated in the tax period is less than VND28 billion and the total value of all related transactions arising in the tax period is less than VND28 billion.
b	Taxpayers who have signed an Advance Agreement on the method of determining taxable prices shall submit an Annual Report in accordance with the law on Advance Agreement on the method of determining taxable prices.
c	Taxpayers conduct business with a simple function, without any revenue, expenses from activities of exploiting and using intangible assets, having turnover below VND8,000 billion, applying the net profit rate before interest and corporate income tax on revenue, including the following areas:
	Distribution: From 5% or more
	Production: From 10% or more
	- Processing: From 15% or more

SECTION III. INFORMATION DETERMINING LINKS TRANSACTION PRICE

Money unit: Vietnam Dong

STT

Write comment here...

Value sold to affiliates

Purchase value from the affiliate

Profit increased due to redefinition of independent transaction prices

Collecting, paying on behalf of, and allocating permanent establishments[3]

Transactions covered by APA[4]

Recorded value of affiliate transaction

The value is redefined according to the independent transaction price

Difference

Method of determining prices

Recorded value of affiliate transaction

The value is redefined according to the independent transaction price

Difference

Method of determining prices

(1)

(2)

(3)

(4)

(5) = (4) - (3)

(6)

(7)

(8)

(9) = (8) - (7)

(10)

(11) = (5) + (9)

(12)

(13)

I

Total transaction value arising from business activities

II

Total transaction value arising from affiliate activities

1

Goods

1.1

Commodities form fixed assets

a

Associated party A

b

Associated party B

...

1.2

Goods do not form fixed assets

a

Associated party A

b

Associated party B

...

2

Services

2.1

Research and Development

a

Associated party A

b

Associated party B

...

2.2

Advertising, marketing

a

Associated party A

b

Associated party B

...

2.3

Business management and consulting, training

a

Associated party A

b

Associated party B

...

2.4

Financial activities

2.4.1

Copyright fees and the like

A

Associated party A

B

Associated party B

....

2.4.2

Interest

A

Associated party A

B

Associated party B

....

2.5

Other services

A

Associated party A

B

Associated party B

....

SECTION IV. RESULTS OF PRODUCTION BUSINESS AFTER THE DETERMINATION OF LINKS TRADING PRICE

1. For taxpayers in production, trade and service industries

Taxpayers have signed prior agreement on tax calculation method (APA)

Yes □

No □

Money unit: Vietnam Dong

STT	Targets	Value of linked transactions		Transaction value with independent parties	Total value arising from business activities in the period
		Values ​​are determined according to the linked transaction price determination dossiers	Value determines the price according to APA
(1)	(2)	(3)	(4)	(5)	(6) = (3) + (4) + (5)
1	Revenue from sales and service provision
	In which: Revenue from sales of exported goods and services
2	The deduction from revenue
3	Net revenue from selling goods and providing services (3)=(1)-(2)
4	Cost of goods sold
5	Gross profit from sales and service provision (5)=(3)-(4)
6	Cost of sales
7	Enterprise Cost Management
8	Revenue from financial activities
8 1	In which: Deposit interest and loan interest
9	Financial expenses
9.1	In which: interest expenses
9.1.a	Interest expense is deducted in the period
9.1.b	The portion of interest expense in the period that is not deductible and carried forward to the next period as prescribed at Point b, Clause 3, Article 16
10	Depreciation expense incurred during the period
11	Net profit from business activities in the period (11)=(5)-(6)-(7)+(8)-(9)
12	Net profit from business activities in the period excluding the difference between revenue and expenses of financial activities (12)=(11)-(8)+(9)
13	Total net profit from business activities plus interest expense after deducting deposit interest and loan interest during the period plus depreciation expense during the period (13)=(11)+(9.1)-(8.1)+(10)
14	Ratio of interest expense after deducting deposit interest and loan interest incurred during the period to total net profit from operating activities plus interest expense after deducting deposit and lending interest in the period plus expenses amortization during the period (14)=[(9.1)-(8.1)]/(13)
15	Interest expense of previous periods is carried over, in which: (15)=(15.1)+(15.2)+(15.3)+(15.4)+(15.5)
15.1	– Interest expense is not deductible from year (n-1) to tax period (n).
15.2	– The non-deductible interest expense from year (n-2) is transferred to tax period (n)
15.3	– Interest expense is not deductible from year (n-3) to tax period (n).
15.4	– Interest expense is not deductible from year (n-4) to tax period (n).
15.5	– Interest expense is not deductible from year (n-5) to tax period (n).
16	Ratio of interest expense after deducting deposit interest and loan interest incurred plus interest expense from previous periods carried over to total net profit from business activities plus interest expense (after deducting deposit interest and loan interest) in the period plus depreciation expense in the period (16)=[(9.1)- (8.1)+(15)]/(13)
17	Rate of return used to determine the price of associated transactions
17.1	– Rate ………………..
17.2	– Rate ………………..
17.3	– …………………….

2. For taxpayers in banking and credit industries

Taxpayers have signed prior agreement on tax calculation method (APA)

Yes □

No □

Money unit: Vietnam Dong

STT	Targets	Value of linked transactions		Transaction value with independent parties	Total value arising from business activities in the period
		Values ​​are determined according to the linked transaction price determination dossiers	Value determines the price according to APA
(1)	(2)	(3)	(4)	(5)	(6) = (3) + (4) + (5)
1	Interest income and similar income
2	Interest expense and similar expenses
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 gain / loss from foreign exchange trading
8	Net gain / loss from trading securities
9	Net gain / loss from trading securities investment
10	Income from other activities
11	Other operating costs
12	Net profit/loss from other activities (12)=(10)-(11)
13	Income from capital contribution, share purchase
14	Operating costs
15	Provision for credit losses
16	Total profit before tax (16)=(3)+(6)+(7)+(8)+(9)+ (12)+(13)-(14)-(15)
17	Net profit from production and business activities (17 = 16-12)
18	Rate of return used to determine the price of associated transactions
18.1	Rate …………….
18.2	Rate …………….
18.3	...........................

3. For taxpayers who are securities companies

Taxpayers have signed prior agreement on tax calculation method (APA)

Yes □

No □

Money unit: Vietnam Dong

STT	Targets	Value of linked transactions		Transaction value with independent parties	Total value arising from business activities in the period
		Values ​​are determined according to the linked transaction price determination dossiers	Value determines the price 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	Gain from financial assets is recognized through profit/loss (FVTPL) (1.1)=(1.1.a)+(1.1.b)+(1.1.c)
1.1.a	Profit from selling financial assets FVTPL
1.1.b	Increased difference in revaluation of assets FVTPL
1.1.c	Dividends and interests arising from financial assets FVTPL
1.2	Gains from hold-to-maturity (HTM) investments
1.3	Interest on loans and receivables
1.4	Gain from financial assets available for sale (AFS)
1.5	Gains from hedging derivatives
1.6	Revenue from securities brokerage operations
1.7	Revenue from underwriting, securities issuance agency
1.8	Revenue from securities investment consulting services
1.9	Revenue from securities depository operations
1.10	Revenue from financial consulting activities
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	Loss of financial assets is recognized through profit/loss (FVTPL) (2.1)=(2.1.a)+(2.1.b)+(2.1.c)
2.1.a	Loss from selling financial assets FVTPL
2.1.b	Difference between revaluation of assets FVTPL
2.1.c	Transaction costs for purchasing financial assets FVTPL
2.2	Losses on hold-to-maturity (HTM) investments
2.3	Loss and revaluation difference at fair value of financial assets available for sale (AFS) upon reclassification
2.4	Cost of provision for financial assets, handling of loss of bad receivables and loss of impairment of financial assets and borrowing costs of loans
2.5	Losses from hedging derivative financial assets
2.6	Self-employment operating expenses
2.7	Securities brokerage service fees
2.8	Fees for underwriting and securities issuance agents
2.9	Professional fees for securities investment consulting
2.10	Securities depository fees
2.11	Cost of financial consulting activities
2.12	Cost of other services
3	Revenue from financial activities (3)=(3.1)+(3.2)+(3.3)+(3.4)
3.1	Realized and unrealized exchange rate difference
3.2	Revenues, dividends, interest on bank deposits are not fixed
3.3	Gains from sale and liquidation of investments in subsidiaries, associates and joint ventures
3.4	Other income from investment
4	Financial cost (4)=(4.1)+(4.2)+(4.3)+(4.4)+(4.5)
4.1	Realized and unrealized exchange rate losses
4.2	Interest expenses
4.3	Losses from sale and liquidation of investments in subsidiaries, associates and joint ventures
4.4	Provision expense for diminution in value of long-term financial investments
4.5	Other financial expenses
5	Cost of sales
6	Securities company management expenses
7	Operation result (7)=(1)-(2)+(3)-(4)-(5)-(6)
8	Total deposit interest and loan interest incurred during the period
9	Total interest expense incurred during the period
9.1	Interest expense is deducted in the period
9.2	The portion of interest expense in the period that is not deductible and carried forward to the next period as prescribed at Point b, Clause 3, Article 16
10	Depreciation expense incurred during the period
11	Total net profit from business activities in the period plus interest expense after deducting deposit interest and loan interest incurred in the period plus depreciation expense incurred in the period [(11)=(7)+(9 )-(8)+(10)]
12	Ratio of interest expense after deducting deposit interest and loan interest incurred during the period to total net profit from operating activities plus interest expense after deducting deposit and lending interest in the period plus expenses Depreciation incurred during the period (12)=[(9)-(8)]/(11)
13	Interest expense of previous periods is carried over to (13)=(13.1)+(13.2)+(13.3)+(13.4)+(13.5) In which:
13.1	– Interest expense is not deductible from year (n-1) to tax period (n).
13.2	– Interest expense is not deductible from year (n-2) to tax period (n).
13.3	– Interest expense is not deductible from year (n-3) to tax period (n).
13.4	– Interest expense is not deductible from year (n-4) to tax period (n).
13.5	– Interest expense is not deductible from year (n-5) to tax period (n).
14	The ratio of interest expense after deducting deposit interest and loan interest incurred and deducted in the period plus interest expense from previous periods transferred to the tax period (n) to the total net profit from business activities plus net interest expense incurred in the period plus depreciation expense incurred in the period of the taxpayer (14) = [(9)-(8)+(13))/(11)
15	Rate of return used to determine the price of associated transactions
15.1	Rate ……………………………
15.2	Rate ……………………………
15.3	.......................................... ..

I certify that the above declared data is correct and I am legally responsible for the declared data.

 

TAX AGENCY STAFF Full name: …………………….. Practice certificate number: ……

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

 

GUIDELINES FOR DECLARATION OF SOME INDICATORS

A. Tax period: Enter information corresponding to the tax period of the corporate income tax finalization declaration. The tax period is determined according to the provisions of the Law on corporate income tax.

B. General information of taxpayers: From target [01] to target [10], write the information corresponding to the information recorded in the enterprise income tax finalization declaration.

C. Section I. Information about related parties:

- Column (2): Write the full name of each related party:

+ In case the affiliate in Vietnam is an organization, write according to the information in the business registration license; As an individual, write the information in the identity card, citizenship card, passport.

+ In case the affiliate is an organization or individual outside Vietnam, write in accordance with the information in the document to determine the linkage such as the business registration license, contract, transaction agreement of the taxpayer with the party. link.

- Column (3): Insert the name of the country or territory where the related party is the resident.

- Column (4): Enter the tax identification numbers of the related parties:

+ In case the affiliate is an organization or individual in Vietnam, write enough tax code.

+ In case the affiliate is an organization or individual outside Vietnam, write the tax code and identification code of the taxpayer, if not, write the reason.

– Column (5): Pursuant to 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 shall 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 shall mark “x” in the corresponding boxes.

D. Section II. Cases exempted from declaration or preparation of transfer pricing documentation:

If the taxpayer is exempted from declaring and preparing the Transfer Pricing Document as prescribed in Article 19 of Decree No. 132/2020/ND-CP in Column (2), mark "x" in the corresponding exemption box in Column (3).

In case the taxpayer is exempted from declaring and preparing transfer pricing dossiers as prescribed in Clause 1, Article 19 of Decree No. 132/2020/ND-CP, the taxpayer only needs to tick the corresponding box in Column (3) and does not have to declare items III and IV of Appendix I attached to Decree No. 20/2025/ND-CP.

If taxpayers are exempt from making dossiers on determination of associated transaction prices according to the provisions of Point a or Point c of 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.

If taxpayers are exempt from making dossiers on determination of associated transaction prices according to the provisions of Point b, Clause 8, Article 2 of Decree No. 19 / 132 / ND-CP, taxpayers shall declare according to the corresponding instructions at part D.2020 and E.

A. Section III. Information on determining the associated transaction price:

D.1. In case the taxpayer is exempted from preparing the Transfer Pricing Document as prescribed in Point a or Point c, Clause 2, Article 19 of Decree No. 132/2020/ND-CP and has declared by marking (x) in column 3 in line a or line c the exemption criteria for preparing the Transfer Pricing Document of Section II, Appendix I attached to Decree No. 20/2025/ND-CP, the taxpayer shall declare this item as follows:

- Columns (3), (7) and (12): Declare as guided in section D.2 of this Appendix.

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

In case the taxpayer is exempted from setting up the dossier of affiliated transaction price as stipulated in Point a, Item 2 Article 19, Decree No. 132 / 2020 / ND-CP, the total value of all associated transactions arises in the tax period as the basis for determining the exempted conditions calculated by (=) the total value in Column (3) plus (+) Column (7) of the target line "Total value of arising transactions from affiliate activities ".

D.2. Taxpayers who are not exempted shall make dossiers on determination of associated transaction prices at Point a or Point c of 2 Article 19 of Decree No. 132 / 2020 / ND-CP declared as follows:

- Target "The total value of transactions arising from business activities":

+ Column (3): Write the total value of sales to the associated parties and independent parties, including: Sales of goods and service provision, revenue from financial activities and other incomes (no including collection).

+ Column (7): Write the total value of expenses payable to the associated parties and independent parties, including: Costs of purchased goods and services, financial costs, selling expenses and expenses business management and other costs (excluding expenditures).

+ Column (4), (5), (6), (8), (9), (10), (11), (12) and (13): Leave blank not declared.

- Target "Total transaction value arising from associated activities":

+ Column (3), (4), (7) and (8): Write the total value in the boxes corresponding to each criterion of Commodity plus (+) Service.

- Target "Goods":

+ Columns (3), (4), (7) and (8): Write the total value in the boxes corresponding to the criteria Goods forming fixed assets plus (+) Goods not forming assets permanent.

– Indicator “Goods forming fixed assets” and detailed lines “Associated Party A”, “Associated Party B”,….:

+ Column (3) and (7): Write the total value arising from buying or selling taxpayers' fixed assets with associated parties according to the value in 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 method of determining associated transaction prices in Column (6) and (ten).

– Indicator “Goods not forming fixed assets” and detailed lines “Associated Party A”, “Associated 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 transfer pricing method in Columns (6) and (10).

- Target "Service":

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

- The indicators "Research and development"; "Advertising and marketing"; "Business management and consulting, training"; "Financial activities and other services", and details for each "Linked party A", "Linked party B", ...:

+ Column (3) and (7): Write the total value of each type of service arising from transactions with associated parties recorded according to the value recorded in the accounting book.

+ Columns (4) and (8): Record the total value of each type of service arising from transactions with related parties determined according to the method of determining related transaction prices in Column (6) and Column respectively. (ten).

– Columns (6) and (10): Record corresponding to each indicator according to each related party the abbreviation of the name of the method for determining the price of related party transactions as prescribed in Articles 13, 14, and 15 of Decree No. 132/2020/ND-CP constituting the selling value to the related party and the purchase value from the related party of the taxpayer determined according to the Transfer Pricing Determination File, specifically as follows:

+ PP1: The method of comparing the associated transaction price with the independent transaction price (the method of comparing the independent transaction price).

+ PP2: Method of comparing the profit rate of taxpayers with the profit rate of independent comparables.

PP2-1: Gross profit margin comparison method (resale price method).

PP2-2: Comparative method of gross profit on cost of goods (cost plus interest method).

PP2-3: Net profit margin comparison method.

+ PP3: Method of profit distribution among related parties.

For example:

+ Purchase machinery from associated party A on the basis of independent transaction price comparison method, in the target line Goods forming fixed assets from related party A Column (10): Enter PP1.

+ Collect fees for management services provided to associated party B on the basis of cost-plus-interest method, at the target line Business management and consulting and training for associated party B Column (6): Enter 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 profit increase due to re-determination according to the independent transaction price.

- Column (12): Enter the total value of collection on behalf of the establishment, the total value of payment on behalf of the household, the total value of revenue attributable to the permanent establishment, the total value of expenses attributable to the permanent establishment arising in the period tax.

– Column (13): Record 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 cells corresponding to the indicator lines recording total value data.

E. Section IV. Business results after determining associated transaction prices:

- Target "The taxpayer has signed a prior agreement on the method of determining the taxable price (APA)":

Taxpayers marked "x" in "Yes" if they signed a single, bilateral or multilateral APA with the Vietnam Tax Authority. In case the taxpayer does not sign APA with the Tax Agency, mark "x" in "No" and leave blank to declare the criteria in Column (4) of the business results table in this section.

- Taxpayers only generate revenues or revenues with independent parties only declared in Column (6) of the table of production and business results suitable to each type of business for each corresponding criterion. instructions in this Appendix.

1. For taxpayers in the production, trade and service industries:

a) In case the taxpayer has declared and marked (x) in Column 3 at line 2a, exempting from preparing the Transfer Pricing Determination File of Section II, Appendix I attached to Decree No. 20/2025/ND-CP, the declaration shall be made according to the following instructions:

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

+ Column (3), (4) and (5): Taxpayer left blank to declare.

+ Column (6): Write the value determined from the data in the Financial Statements.

– 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 in Point a, Point b, Clause 3, Article 16 of Decree No. 132/2020/ND-CP.

- Target in line (17): The taxpayer leaves the declaration blank.

b) In case the taxpayer has declared and marked (x) in Column 3 at line 2c, exempting from preparing the Transfer Pricing Determination File of Section II, Appendix I attached to Decree No. 20/2025/ND-CP, the declaration shall be made according to the following instructions:

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

+ Column (3), (4) and (5): Taxpayer left blank to declare.

+ Column (6): Write the value determined from the data in the Financial Statements.

– 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 in Point a, Point b, Clause 3, Article 16 of Decree No. 132/2020/ND-CP.

- Target "The rate of return used to determine the associated transaction price"

+ Column (2): Record the net profit margins from production and business activities during 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.

+ Column (3), (4) and (5): Taxpayer left blank to declare.

+ Column 6: Taxpayers declare the value of Net profit from production and business activities in the period excluding the difference between revenue and expenses of financial activities on net revenue for the field of operation as prescribed in Point c, Clause 2, Article 19 of Decree No. 132/2020/ND-CP.

In case taxpayers conduct business in more than one field, separately monitor and account revenues and expenses of each field or separately monitor and account revenue but cannot monitor and separately account expenses. Costs incurred by each field shall be declared separately for each field.

In case taxpayers conduct business in more than one field without monitoring, the revenue and expenses of each field shall be separately recorded and declared according to the field with the highest rate.

c) In case the taxpayer is not exempted from preparing the Transfer Pricing Document as prescribed in Point a or Point c, Clause 2, Article 19 of Decree No. 132/2020/ND-CP, declare as follows:

- Target "Sales of goods and services":

+ Column (3) and (4): Write the total value of the transactions of supplying goods and services to the related parties to determine the price according to the dossier of affiliated transaction price determination in Column (3) and follow APA in Column (4).

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

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

Indicators "Revenue from sales of exported goods and services" and "Revenue deductions": Taxpayers declare corresponding revenue from sales of goods and provision of services and record according to similar instructions in the indicator "Revenue from sales of goods and provision of services".

- Target "Net revenue from selling goods and providing services":

+ Column (3), (4), (5) and (6): Write the value equal to each value in the column "Sales and service provision" except (-) target " The deduction from revenue".

- Target "Cost of goods sold":

+ Column (3) and (4): Write the total value of the cost of goods sold corresponding to the sales and service provision for the associated parties and equal (=) the total value of arising with the related parties. The result is determined according to the associated transaction price determination dossier and according to APA plus (+) value of arising transactions with independent parties recorded in the accounting book.

+ Column (5): Write the total value of the cost of goods sold corresponding to sales and service provision for independent parties and equal (=) the total value generated with the affiliated parties determined according to Records of determining the associated transaction prices and according to APA plus (+) value of arising transactions 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.

- Target "Gross profit from sales and service provision":

+ Column (3), (4), (5) and (6) are equal to the corresponding value according to each column in the index "Net revenue from sales and service provision" minus (-) the target "Cost of goods sold".

- The criteria "Selling expenses" and "Expenses for business management":

+ Column (3) and (4): Write the total value of selling expenses, enterprise management costs corresponding to sales and service provision to the associated parties equal to (=) total value arises with affiliated parties to determine according to the associated transaction price determination dossier and according to APA plus (+) value of arising transactions with independent parties recorded in the accounting book.

+ Column (5): Write the total value of selling expenses, enterprise management expenses corresponding to sales revenue and service provision to independent parties equal to (=) the total value arising from the The affiliated party determines according to the associated transaction price determination dossier and according to APA plus (+) value of arising transactions with independent parties recorded in the accounting book.

+ 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 production and business activities, the taxpayer shall monitor the accounting and record the accounting value, and determine separately the expenses from the related party under the price determination scope. Transfer pricing documentation file; According to the APA and transactions with independent parties corresponding to columns (3), (4) and (5). If the taxpayer cannot determine the most appropriate allocation criteria for one or more factors such as revenue, expenses, assets, human resources or other factors consistent with the nature of the operation. and record the value of the amortization expenses in the boxes (3), (4) and (5), respectively.

- Target "Revenue from financial activities":

+ Column (3), (4) and (5): Taxpayer left blank to declare.

+ Column (6): Write the total value of revenue from financial activities.

– Target “Deposit interest and loan interest”: Record the value of interest earned from lending activities included in financial income in the period.

+ Column (3), (4) and (5): Taxpayer left blank to declare.

+ Column (6): Write the total value as determined in the dossier of affiliated transaction price determination, according to APA for arising transactions with associated parties and the value recorded in accounting books for transacting transactions. born with independent parties.

- Target "Financial expenses":

+ Column (3), (4) and (5): Taxpayer left blank to declare.

+ Column (6): Write the total value of financial activities.

– Target “Expense of interest on loans used for production and business activities”: Record the value of loan interest expenses included in financial expenses in the period.

+ Column (3), (4) and (5): Taxpayer left blank to declare.

+ Column (6): Write the total value as determined in the dossier of affiliated transaction price determination, according to APA for arising transactions with associated parties and the value recorded in accounting books for transacting transactions. born with independent parties.

– Target “Depreciation expense incurred in the period”:

+ Column (3), (4) and (5): Taxpayer left blank to declare.

+ Column (6): Write the total value of depreciation expenses calculated into the expenses in the period and is determined by the total value of depreciation expenses already included in cost of goods sold, selling expenses and management expenses. enterprise.

– Target “Net profit from production and business activities in the period”:

+ Column (3), (4) and (5): Taxpayer left blank to declare.

+ Column (6): Write the value equal to the value of each column at the index "Gross profit on selling goods and providing services" except (-) "Sales cost" target minus (-) only "Enterprise management cost" plus (+) target "Financial revenue" minus (-) the target "Financial expenses".

– Target “Net profit from production and business activities in the period excluding the difference between revenue and expenses of financial activities”:

+ Column (3), (4), (5) and (6): Write the value equal to the value of each column at the index "Gross profit on sales and service provision" minus (-) only "Selling expenses" target minus (-) the "Enterprise management expense" target.

– Target “Total net profit from business activities plus interest expense after deducting deposit interest and loan interest in the period plus depreciation expense in the period”:

+ Column (3), (4) and (5): Taxpayer left blank to declare.

+ Column (6): Enter the value equal to the target value "Net profit from production and business activities" plus (+) the item "Loan interest expenses" minus (-) the target "Deposit interest and interest loans” plus (+) the indicator “Depreciation expenses”.

– Target “The ratio of interest expense after deducting deposit interest and lending interest incurred during the period to total net profit from business activities plus interest expense after deducting deposit interest and lending interest in the period.” period plus depreciation expense for the period”:

+ Column (3), (4) and (5): Taxpayer left blank to declare.

+ Column (6): Enter the percentage value equal to (=) the value of [the item "Loan interest expense" minus (-) the item "Deposit interest and loan interest"] divided (:) the price Target value "Total net profit from business activities plus interest expense after deducting deposit interest and loan interest in the period plus depreciation expense in the period".

- Target "The rate of profit used to determine the associated transaction price":

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

+ Column (3) and (4): Write the value of profit rate used to determine the associated transaction price according to the dossier of affiliated transaction price determination at Column (3) and according to APA in Column (4).

+ Column (5) and (6): Taxpayer left blank to declare.

For example:

+ Taxpayers use the net profit ratio comparison method and apply Net profit from production and business activities in the period excluding the difference between revenue and expenses of financial activities on total expenses to To determine the net profit in the tax period, in Column (2), item (17.1): Record the net profit from production and business activities in the period excluding the difference between revenue and expenses of the above financial activities. the total cost and declare the corresponding rate according to the associated transaction price determination dossier in Column (3) and according to the APA in Column (4).

+ Taxpayers use the net profit ratio comparison method and apply Net profit from production and business activities in the period excluding the difference between revenue and expenses of financial activities on total expenses for with production activities according to the associated transaction price determination dossier; Net profit from business activities in the period does not include the difference between revenue and expenses of financial activities on net revenue from distribution activities according to APA, in Column (2) of target (17.1) and (17.2): Record net profit from production and business activities in the period excluding the difference between revenue and expenses of financial activities over total costs for production activities at target (17.1) and declare the corresponding ratio in Column (3); Record Net profit from production and business activities in the period excluding the difference between revenue and expenses of financial activities on net revenue from distribution activities at target (17.2) and declare the corresponding ratio. corresponding to Column (4).

- In case the taxpayer performs many production and business functions and the profit margin used to determine the transfer price is different, then declare the production and business results after determining the transfer price. separately for each production and business function.

2. For taxpayers in banking and credit industries:

- Target "Interest income and similar incomes":

+ Column (3), (4) and (5): Write the total value of interest income and similar incomes from non-APA affiliates determined according to the associated transaction price determination dossier at Column (3), according to APA in Column (4) and follow the value of the accounting book generated with the independent side 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.

– Target “Interest expenses and similar expenses”:

+ Column (3) and (4): Write the total value of interest payment and similar expenses corresponding to interest income and similar income obtained from the associated parties and equal (=) total Value arising with affiliated parties determined by Associated Transaction Price Determination Records and according to APA plus (+) value of arising transactions with independent parties recorded in the accounting books.

+ Column (5): Write the total value of interest payments and similar expenses corresponding to interest income and similar income obtained from independent parties equal to (=) the total value arising from The affiliated parties determine according to the associated transaction price determination dossier and according to APA plus (+) value of arising transactions with independent parties recorded in the accounting book.

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

- Target "Net interest income":

Column (3), (4), (5) and (6): Write the value equal to (=) the corresponding value according to each column at the target Interest income and similar incomes except (-) indicator Interest payments and similar expenses.

- Target "Income from service activities": Record according to the same guidance in the target Interest income and similar incomes.

- Target "Service expenses": Record according to the same guidance in the item Interest payment and similar expenses.

- Target "Net profit / loss from service activities":

Column (3), (4), (5) and (6): Write the value equal to (=) the corresponding value according to each column at the index "Income from service activities" minus (-) the target " Service operation costs ”.

- The indicators "Net gain / loss from foreign exchange trading", "Net gain / loss from trading securities", "Net gain / loss from trading investment securities": Record according to the instructions. similar to the index "Interest income and similar income".

- Target "Income from other activities": Write according to the same guidance in the index "Interest income and similar incomes".

- Target "Other operating expenses": Record according to the same guidance in the item Interest payment and similar expenses.

- Target "Net profit / loss from other activities":

Column (3), (4), (5) and (6): Write the value equal to (=) the corresponding value according to each column in the index "Income from other activities" minus (-) the target "Chi Other operating fees ".

- Target "Income from capital contribution, share purchase": Write according to the same guidance in the target "Interest income and similar incomes".

- Target "Operating expenses": Record according to the same guidance in the "Payment of interests and similar expenses" index.

- Target "Expenses for provision for credit risks":

+ Column (3), (4) and (5): Write the total value of credit risk provision expenses corresponding to income and revenues that are revenue in column (3), (4) and (5) for provision.

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

- For items of expenses arising in business activities, taxpayers shall account and determine separately corresponding to each revenue that is revenue in columns (3), (4), (5). ) and record the value separately calculated and determined. If the taxpayer cannot determine the most appropriate allocation criteria for one or more factors such as revenue, expenses, assets, human resources or other factors consistent with the nature of the operation. and record the value of the amortization in the boxes (3), (4) and (5), respectively.

- Target "Total profit before tax": Reflecting the total profit before tax of a banking or credit institution in the tax period and is determined as follows:

+ Column (3), (4), (5) and (6): Write the value equal to (=) the corresponding value according to each column at the index "Net interest income" plus (+) the target "Interest / Net loss from service activities ”plus (+) target" Net gain / loss from foreign exchange trading activities "plus (+) target" Net gain / loss from trading securities "plus (+) indicator "Net gain / loss from trading securities investment" plus (+) index "Net gain / loss from other activities" plus (+) target "Income from capital contribution, share purchase" minus ( -) "Operating expenses" target minus (-) the "Credit risk provision expense" target.

- Target: "Net profit from production and business activities":

+ Column (3), (4), (5) and (6): Write the value equal to each value according to the column "Total profit before tax" minus (-) the target "Net gain / loss" from other activities ”.

- Target "The rate of profit used to determine the associated transaction price":

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

+ Column (3) and (4): Write the value of profit rate applied to determine the associated transaction price according to the dossier of affiliated transaction price determination at Column (3) and according to APA in Column (4).

+ Column (5) and (6): Taxpayer left blank to declare.

3. For taxpayers who are securities companies:

a) In case the taxpayer has declared and marked (x) in Column 3 in line 2a, Section II, Appendix I attached to Decree No. 20/2025/ND-CP, make the declaration according to the following instructions:

– Indicators at 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):

+ Column (3), (4) and (5): Taxpayer left blank to declare.

+ Column (6): Write the value determined from the data in the Financial Statements.

- Target in line (15): The taxpayer leaves the declaration blank.

b) In case the taxpayer is not exempted from preparing the Transfer Pricing Document as prescribed in Point a, Clause 2, Article 19 of Decree No. 132/2020/ND-CP, declare as follows:

– Indicators at 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):

+ Column (3), (4) and (5): Write the total value of interest income and similar incomes from non-APA affiliates determined according to the associated transaction price determination dossier at Column (3), according to APA in Column (4) and follow the value of the accounting book generated with the independent side 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 expenses incurred in the period, taxpayers keep track of accounting and record the accounting value, determine separately for costs from related parties within the scope of price determination according to the valuation dossier. related transactions; under the APA and dealing with independent parties in columns (3), (4) and (5) respectively. If it cannot be determined separately, the taxpayer shall choose the most appropriate allocation criterion according to one or several factors such as revenue, expenses, assets, human resources or other factors suitable to the nature of operations. and write the value of the allocated cost in the corresponding boxes (3), (4) and (5).

– Target “Total net profit from business activities in the period plus interest expense after deducting deposit interest and loan interest incurred in the period plus depreciation expense incurred in the period”:

+ Column (3), (4) and (5): Taxpayer left blank to declare.

+ Column (6): Enter the value equal to the target value "Operating results" plus (+) the indicator "Total interest expenses incurred in the period" minus (-) "Total interest on deposits and loans incurred in the period" plus (+) the item "Depreciation expenses incurred in the period".

– Target “The ratio of interest expense after deducting deposit interest and lending interest incurred in the period to total net profit from business activities plus interest expense after deducting deposit interest and lending interest in the period.” period plus depreciation expense incurred in the period”:

+ Column (3), (4) and (5): Taxpayer left blank to declare.

+ Column (6): Record the percentage value equal to (=) the value (indicator "Total loan interest expense" minus (-) the indicator "Total deposit interest and loan interest"] divided by (:) the value of the indicator "Net profit from business activities plus loan interest expense plus depreciation expense incurred during the period".

- Target "The rate of profit used to determine the associated transaction price":

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

+ Column (3) and (4): Write the value of profit rate applied to determine the associated transaction price according to the dossier of affiliated transaction price determination at Column (3) and according to APA in Column (4).

+ Column (5) and (6): Taxpayer left blank to declare.

 

[1] Taxpayers mark “x” in the column of the form of related-party relationship declared according to the provisions of Clause 2, Article 5 of Decree No. 132/2020/ND-CP dated November 05, 11 of the Government and Article 2020 of Decree No. 1/20/ND-CP dated February 2025, 10 of the Government. In case the related party belongs to more than one form of related-party relationship, the taxpayer marks “x” in the corresponding boxes.

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

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

[4] Taxpayers declare “x” for transactions covered by APA and “no” for transactions not covered by APA.