WONE Global's guide to Vietnam records this change under tax and reporting. Each statement below has been checked against the source it links to.
Under the transfer pricing rules, parties are related at 25% ownership and deductible interest is capped at 30% of EBITDA; Decree 255/2026 replaces Decree 132/2020 from 1 July 2026, applying from the 2026 tax period.
Master file, local file and CbC report requirements apply, with exemptions below revenue thresholds not stated in the source. Whether the interest cap carries over under Decree 255 was not confirmed.
PwC Worldwide Tax Summaries · Vietnam - Corporate - Group taxation ↗ Checked against a secondary source · Not yet professionally reviewed · checked 19 October 2026
This is a summary of the rule as published, not advice on how it applies to you. The WONE Global Partner for this service in Vietnam can advise on that.











