Vietnam: Decree 20 vtv5 trực tiếp bóng đá hôm nay 2025 replaces Appendix I on related-party transactions vtv5 trực tiếp bóng đá hôm nay Decree 132

Vietnam: Decree 20 vtv5 trực tiếp bóng đá hôm nay 2025 replaces Appendix I on related-party transactions vtv5 trực tiếp bóng đá hôm nay Decree 132

The Government vtv5 trực tiếp bóng đá hôm nay Vietnam has recently issuedNghị định 20/2025/NĐ-CP, which amends and supplements certain articles vtv5 trực tiếp bóng đá hôm nayNghị định 132/2020/NĐ-CPconcerning tax management for enterprises engaging in related-party transactions.

Decree 20 vtv5 trực tiếp bóng đá hôm nay 2025 will take effect on March 27, 2025, and will be applicable from the 2024 corporate income tax period.

Decree 20 vtv5 trực tiếp bóng đá hôm nay 2025 issued Appendix I toreplaceAppendix I Information on Associated Relationships and related-party transactions issued withDecree 132/2020/ND-CP.

The content vtv5 trực tiếp bóng đá hôm nay Appendix I issued withNghị định 20/2025/NĐ-CPconsists vtv5 trực tiếp bóng đá hôm nay four sections as follows:

- Section I: Information on affiliated parties;

- Section II: Cases exempt from declaration and preparation vtv5 trực tiếp bóng đá hôm nay related-party transactions documentation;

- Section III: Information to determine related-party transactions;

- Section IV: Business results after determination vtv5 trực tiếp bóng đá hôm nay related-party transactions.

In addition to the four sections above, detailed guidance on how to declare the indicators is included.

Thus, enterprises will officially apply the template for Information on Associated Relationships and related-party transactions in Appendix I issued withNghị định 20/2025/NĐ-CPfrom the 2024 corporate income tax period.

Vietnam: Decree 20 vtv5 trực tiếp bóng đá hôm nay 2025 replaces Appendix I on related-party transactions vtv5 trực tiếp bóng đá hôm nay Decree 132(Image from the Internet)

What are the principles for related-party transactions in Vietnam?

According to Article 3 vtv5 trực tiếp bóng đá hôm nayDecree 132/2020/ND-CP, the principles for applying related-party transactions are specified as follows:

- Taxpayers with related-party transactions must eliminate factors that reduce tax obligations due to influence or control by associated relationships to declare and determine tax obligations for related-party transactions equivalent to independent transactions under similar conditions.

- Tax authorities manage, inspect, and audit taxpayers' related-party transactions according to the principle vtv5 trực tiếp bóng đá hôm nay independent transactions and the nature vtv5 trực tiếp bóng đá hôm nay activities and transactions deciding tax obligations corresponding to the values created from the nature vtv5 trực tiếp bóng đá hôm nay those transactions, not recognizing related-party transactions that do not follow the principle vtv5 trực tiếp bóng đá hôm nay independent transactions that reduce business tax obligations to the state budget, and make adjustments to those transfer prices to correctly determine tax obligations as prescribed byNghị định 132/2020/NĐ-CP.

What are procedures fordetermination vtv5 trực tiếp bóng đá hôm nay costs for tax calculation for enterprises with related-party transactions in Vietnam?

According to Article 16 vtv5 trực tiếp bóng đá hôm nayDecree 132/2020/ND-CP, the determination vtv5 trực tiếp bóng đá hôm nay costs for tax calculation for enterprises with related-party transactions is as follows:

(1)Costs vtv5 trực tiếp bóng đá hôm nay related-party transactions not in line with the nature vtv5 trực tiếp bóng đá hôm nay independent transactions or not contributing to revenue and income generation for the taxpayer's production and business activities are not deductible when determining taxable corporate income, including:

- Payments to affiliated parties not involved in any production, business activities related to the taxpayer's industry, activities; having no interest or responsibility regarding assets, goods, services provided to the taxpayer;

- Payments to affiliated parties conducting production or business activities but with asset scale, employee number, and production and business functions not commensurate with the transaction value received from the taxpayer;

- Payments to affiliated parties residing in countries or territories not imposing corporate income tax, not contributing to the taxpayer's revenue, added value in production and business activities.

(2)Service costs between affiliated parties:

- Except for expenses specified at point b, clause 2, Article 16Decree 132/2020/ND-CP, taxpayers can deduct service costs in the taxable expenses for the period if they meet the following conditions: The service provided has commercial, financial, economic value and directly serves the taxpayer's production and business activities; services from affiliated parties are identified as provided under conditions similar to those independent parties pay for these services; the service fee is paid based on the principle vtv5 trực tiếp bóng đá hôm nay independent transactions and the related-party transactions calculation method or allocation vtv5 trực tiếp bóng đá hôm nay service fees among affiliated parties must be uniformly applied within the entire group for similar services, and the taxpayer must provide contracts, documents, invoices, and information about the calculation method, allocation factors, and pricing policy vtv5 trực tiếp bóng đá hôm nay the group for the provided services.

In cases involving centers performing specialized function and synergy to create added value vtv5 trực tiếp bóng đá hôm nay the group, taxpayers must determine the total value created from these functions, determine an appropriate profit allocation corresponding to the contributions vtv5 trực tiếp bóng đá hôm nay affiliated parties after deducting (-) the equivalent service fee for affiliated parties performing coordination functions, providing services vtv5 trực tiếp bóng đá hôm nay similar independent transactions.

- Service costs are not deductible when determining taxable income, including: Costs incurred from services provided solely for the benefit or create value for other affiliated parties; services serving the interests vtv5 trực tiếp bóng đá hôm nay shareholders vtv5 trực tiếp bóng đá hôm nay affiliated parties; duplicate service charges provided by multiple affiliated parties for the same type vtv5 trực tiếp bóng đá hôm nay service, without determining any added value for the taxpayer; services essentially benefits received due to being a member vtv5 trực tiếp bóng đá hôm nay a group and costs that affiliated parties add for services provided by third parties through intermediaries not contributing additional value to the services.

(3)Total deductible loan interest expenses when determining taxable corporate income for enterprises with related-party transactions:

- Total loan interest expenses after deducting interest from deposits and loans incurred during the period, can be deducted when determining taxable corporate income, not exceeding 30% vtv5 trực tiếp bóng đá hôm nay the total net profit from business activities in the period plus loan interest expenses after deducting interest from deposits and loans incurred during the period plus depreciation expenses incurred during the taxpayer's period;

- The portion vtv5 trực tiếp bóng đá hôm nay non-deductible loan interest expenses as specified in point a vtv5 trực tiếp bóng đá hôm nay this clause can be carried forward to the next tax period when determining the total deductible loan interest expenses if the deductible expenses in the next tax period fall short vtv5 trực tiếp bóng đá hôm nay the cap specified in point a, clause 2, Article 16 vtv5 trực tiếp bóng đá hôm nayDecree 132/2020/ND-CP. The continuous carry-forward period for undeducted loan interest expenses is up to 5 years from the year following the year the expenses were incurred;

- The regulation at point a, clause 2, Article 16Decree 132/2020/ND-CPdoes not apply to loans vtv5 trực tiếp bóng đá hôm nay taxpayers who are credit institutions under the Law on Credit Institutions; insurance business organizations under the Law on Insurance Business; official development assistance (ODA) loans, preferential loans vtv5 trực tiếp bóng đá hôm nay the Government vtv5 trực tiếp bóng đá hôm nay Vietnam for businesses to relend; loans for implementing national target programs (new rural development program and sustainable poverty reduction); loans for investment programs, projects executing the social welfare policies vtv5 trực tiếp bóng đá hôm nay the state (resettlement housing, housing for workers, students, social housing, and other public welfare projects);

- Taxpayers declare the interest expense ratio in the tax period according to Appendix I issued withDecree 132/2020/ND-CP.