On 10 February 2025, the Vietnamese Government has issued Decree No. 20/2025/ND-CP (Decree 20/2025) to amend certain Articles provide under Decree 132/2020/ND-CP (Decree 132/2020) regarding Tax administration of enterprises engaging in related party transaction. Decree 20/2025 will come into effect on 27 March 2025 and apply from tax year 2024.

Summary on noteworthy points:

The following content will summarize the notable amendments provided under Decree 20/2025 for your ease of reference:

In addition, Decree 20/2025 has also provided a new template of Appendix I - Disclosure of Related party and Related party transaction. This new template will replace the current template as provided under Decree 132/2020.

Transitional rules

Transitional rules will apply for tax years 2020, 2021, 2022 and 2023. Taxpayers only incur related party borrowing transaction with financial institution as regulated under Decree 132/2020 subject to disqualifications conditions provided under Decree 20/2025 are allowed to allocate non-deductible and non-transferred expenses toward upcoming period per guidance.

Recommendation from Grant Thornton Vietnam:

  • Review the related party/parties who are financial institutions and conduct proper disclosure from tax year 2024
  • Review the non-deductible and non-transferred interest expenses in 2020-2023 and plan properly for transferrability purposes in case of qualification
  • Review the compliant status of branch(es) with independent accounting and prepare necessary compliant document from tax year 2024
  • Consult with tax advisors on further impacts of Decree 20/2025 for more detailed and professional guidance

Grant Thornton (Vietnam) Limited will continue updating Decree 20/2025 and associated impacts with more details in our subsequent publications. Should you need further clarification on the above matters, please do not hesitate to contact us for discussion.

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Hoang Khoi
Partner, Head of Tax Services
Hoang Khoi
Do Vu Bao Khanh
Director, Transfer pricing services
Do Vu Bao Khanh