Lao PDR

Group taxation is not permitted, and each entity must file its own separate tax return.

Transfer pricing

Currently, there are no effective transfer pricing regulations in Laos. The tax authorities retain the right to assess transactions if they determine that such transactions are not conducted at fair market value or on reasonable terms. Additionally, no official guidelines regarding market rates or reasonable pricing have been issued by the authorities.

However, the tax authority is currently in the process of studying and drafting relevant transfer pricing (TP) guidelines, which are presently under discussion and preparation among the related authorities.

Thin capitalisation

There are no specific thin capitalisation rules in the Lao Tax Law. However, the Law on Investment Promotion No 14/NA (Investment Law), dated 17 November 2016, provides that the registered capital of companies availing of the incentives shall not be less than 30% of the total capital. 

Under the Decision on Contribution to Registered Capital No. 2025/MoIC, dated 9 September 2025, Article 6 is required all registered entity to fully contributed the registered capital both in cash and in kind within one year starting from the registered dated.

Controlled foreign companies (CFCs)

There is no CFC or similar regime in Lao PDR.