Country-by‑Country Reporting – Compilation of 2026 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 (UPEs) / On demand (local filing)

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	None.
Appropriate use	Not reviewed.

The domestic legal and administrative framework

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 standard.1 This recommendation remains in place since the 2022/2023 peer review.

The exchange of information framework

Viet Nam’s 2024/2025 peer report included a recommendation 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. Viet Nam has activated exchange relationships under the Multilateral Competent Authority Agreement for the exchange of CbC reports. This recommendation is removed.

Viet Nam’s 2018/2019 peer report included a recommendation 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. These processes are now in place and the recommendation is removed.

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.

For information, Viet Nam has provided details of the controls it has in place to ensure the appropriate use of CbC reports, which comply with published Guidance on the Appropriate Use of Information Contained in CbC Reports.

Note

← 1.  Viet Nam’s 2021/2022 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.