Decree 253/2026/ND-CP

Summary

Decree 253/2026/ND-CP was promulgated to establish a solid legal framework for tax administration regarding enterprises with associated transactions, particularly multinational corporations and companies with complex ownership structures. The decree updates and internalizes the latest international standards on Base Erosion and Profit Shifting (BEPS). The document specifies methods for determining associated transaction prices, mandatory requirements for preparing national files, global files, and country-by-country reports. Concurrently, the decree sets limits on deductible interest expenses when calculating CIT, outlines cases exempt from preparing associated transaction dossiers, and details the responsibilities of tax authorities in inspecting, auditing, and filtering transfer pricing risks.