Vietnam witnessed the most significant developments related to transfer pricing. Following the establishment of a transfer pricing audit department in the General Department of Taxes (GDT) and some key provinces such as Hanoi, Binh Duong, Dong Nai, and Ho Chi Minh City, in July 2016, the GDT announced the establishment of a Base Erosion and Profit Shifting (BEPS) Working Group, which is responsible for preparing action plans to implement the Organisation for Economic Co-operation and Development (OECD) BEPS Initiatives and overseeing the implementation process.
In 2017, the Vietnamese government released Transfer Pricing Decree No. 20/2017/ND-CP guiding the implementation of transfer pricing (Decree 20) and guiding circular 41/2017/TT-BTC (Circular 41), which entered into effect from 1 May 2017. In 2018 and 2019, various rulings guiding the implementation of Decree 20 and Circular 41 have been issued.
There is also a new decree on e-invoices, which aims to promote the use of e-invoices by most taxpayers.
Recently, the Ministry of Planning and Investment has released a draft Law amending and supplementing some articles of the Law on Investment and the Law on Enterprise. The draft law has proposed some changes to the existing Law on Investment and the Law on Enterprise.
The amended Tax Admin Law was approved in June 2019 and will take effect from 1 July 2020, except for provisions relating to e-invoices and electronic documents, which will be effective from 1 July 2022.
In addition, the draft amendments to the Labour Code are scheduled to be finalised and passed around the end of 2019 and come into effect from 1 January 2021.