Vietnam issues guidance on CbC reporting through automatic exchange of information

Vietnam's General Department of Taxation has issued guidance on the implementation of Country-by-Country Reporting (CbCR) exchange relationships under the OECD framework, confirming when reports will be exchanged automatically and identifying 37 jurisdictions with activated exchange arrangements.

Vietnam’s General Department of Taxation has issued guidance on the implementation of Country-by-Country Reporting (CbCR) exchange relationships under the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA), clarifying Vietnam’s exchange relationships with 37 jurisdictions.

The guidance, set out in Official Letter No. 3810/CT-CS dated 10 June 2025, clarifies when the Vietnamese tax authority will receive CbC reports through the automatic exchange of information instead of requiring local filing by taxpayers.

Filing requirements

The guidance states that if a Vietnamese taxpayer’s Ultimate Parent Entity (UPE) is resident in a jurisdiction that has an activated exchange relationship with Vietnam and is required to file a Country-by-Country Report in that jurisdiction, the Vietnamese tax authority will receive the report through the automatic exchange of information. In these cases, the Vietnamese taxpayer is not required to submit a separate Country-by-Country Report in Vietnam.

The official letter also refers to proposed amendments to Decree No. 132/2020/ND-CP concerning taxpayers’ rights and obligations relating to transfer pricing documentation and Country-by-Country Reporting.

Jurisdictions with activated exchange relationships

According to the appendix to the official letter, updated on 17 April 2026, Vietnam has activated Country-by-Country Reporting exchange relationships with the following jurisdictions (37 jurisdictions):

Exchange relationships with China, Croatia, Hong Kong (China), Latvia and Russia apply to fiscal years beginning on or after 1 January 2024.