On 5 June 2018, the Government submitted the draft of law amending the Revenue Code on transfer pricing to the National Legislative Assembly for approval.

The draft law clarifies that taxpayers who meet the income threshold must prepare and submit an annual report that discloses the relationship between related parties and the amount of related party transactions, regardless of whether that relationship persists throughout the entire accounting period, or whether the related parties had any inter-company transactions during the year.

The law will be in force for the accounting periods beginning on or after 1 January 2019. The first filing date of the transfer pricing disclosure form which will need to be filed with an annual tax return will be on 30 May 2020 for the fiscal year ended 31 December 2019 and 28 August 2020 for the fiscal year ended 31 March 2020.