Country-by‑Country Reporting – Compilation of 2025 Peer Review Reports

Viet Nam

Overview of CbC reporting requirements

First reporting fiscal year: Commencing on or after 1 May 2017

Consolidated group revenue threshold: VND 18,000 billion

Filing deadline: 12 months following the end of the reporting fiscal year

Local filing required: Yes

Surrogate parent entity filing permitted: Yes

First review of the domestic legal framework: 2018-2019

Summary of recommendations

 

Area of implementation	Recommendations for improvement
Domestic legal and administrative framework	It is recommended that Viet Nam take steps to ensure that local filing only occurs in the circumstances permitted under the minimum standard.
Exchange of information framework	It is recommended that Viet Nam continue to work actively towards having in place qualifying competent authority arrangements with jurisdictions of the Inclusive Framework that meet the confidentiality, consistency and appropriate use conditions, and with which Viet Nam has an agreement in effect that allows for the automatic exchange of information. It is recommended that Viet Nam take steps to implement processes or written procedures to ensure that the exchange of information is conducted in a manner consistent with the terms of reference relating to the exchange of information framework as soon as possible.
Appropriate use	Not reviewed.

The domestic legal and administrative framework

Viet Nam’s 2018-2019 peer review recommended that Viet Nam amend its legislation or otherwise take steps to ensure that enforcement provisions relating to effective implementation of filing requirement for CbC reporting are provided for as required by the terms of reference as soon as possible. Viet Nam has clarified that it has enforcement provisions in place and the recommendation is removed.1

Viet Nam has a legislative requirement for local filing which is in effect despite Viet Nam not yet meeting all of the consistency, confidentiality and appropriate use conditions. It is therefore recommended that Viet Nam take steps to ensure that local filing only occurs in the circumstances permitted under the minimum standard2. This recommendation remains in place since the 2022-2023 peer review.

The exchange of information framework

Viet Nam’s 2018-2019 peer report included a recommendation that Viet Nam take steps to have qualifying competent authority agreements in effect with jurisdictions of the Inclusive Framework which meet the confidentiality, consistency and appropriate use conditions and with which it has an international exchange of information agreement in effect that allows for the automatic exchange of tax information.

Viet Nam has activated a number of relationships under the Multilateral Competent Authority Agreement for the exchange of CbC reports. It is recommended that Viet Nam continue to work actively towards having in place qualifying competent authority arrangements with jurisdictions of the Inclusive Framework that meet the confidentiality, consistency and appropriate use conditions, and with which Viet Nam has an agreement in effect that allows for the automatic exchange of information.

It is recommended that Viet Nam take steps to implement processes or written procedures to ensure that the exchange of information is conducted in a manner consistent with the terms of reference relating to the exchange of information framework as soon as possible. This recommendation remains in place since the 2018-2019 peer review.

Appropriate use of CbC reports

Viet Nam is a non-reciprocal jurisdiction and, as such, will not receive CbC reports submitted to tax authorities in other jurisdictions. It is therefore not necessary for this peer review evaluation to reach any conclusion with respect to Viet Nam’s compliance with the terms of reference on appropriate use.

Notes

← 1.  https://vbpl.vn/TW/Pages/vbpq-van-ban-goc.aspx?ItemID=146458.

← 2.  Viet Nam’s 2021/22 peer review included a monitoring point with respect to the conditions under which local filing may be required (paragraph 8 (c) iv. c) of the terms of reference). This monitoring points remain in place.