International tax: Related-party transactions & Global minimum tax

Enterprises transacting with related parties (parent companies, subsidiaries, foreign branches) must comply with Decree 132/2020/ND-CP (as amended by Decree 20/2025/ND-CP) on the arm's length principle, including the obligation to declare related-party transaction information and to prepare transfer pricing documentation (Local File, Master File and Country-by-Country Report depending on scale). In parallel, multinational groups with consolidated revenue of EUR 750 million or more fall within the scope of the Global minimum tax under Resolution 107/2023/QH15, with a minimum rate of 15% applied through the Qualified Domestic Minimum Top-up Tax (QDMTT) and the Income Inclusion Rule (IIR) from financial year 2024. The service helps enterprises assess whether they are in scope, prepare the compliance file and calculate any top-up tax due.

• Reviewing and identifying related parties under Decree 132/2020 (as amended by Decree 20/2025)
• Preparing transfer pricing documentation (Local File and Master File) on the arm's length principle
• Declaring related-party transaction information in the annual CIT finalisation return
• Assessing whether the Global minimum tax applies (EUR 750 million consolidated revenue threshold)
• Calculating the Qualified Domestic Minimum Top-up Tax (QDMTT) and the impact of the IIR
• Reviewing existing investment incentives in the context of the Global minimum tax
• Preparing files and explanations for tax audits of related-party transactions
• Updates on new guidance documents in this area