Vietnam’s Department of Taxation has issued guidance on Country-by-Country Reporting obligations, confirming that CbC Reports filed by foreign Ultimate Parent Entities in jurisdictions with activated exchange relationships will be received through the Automatic Exchange of Information mechanism rather than direct submission by taxpayers.
Vietnam’s Department of Taxation has released Official Letter No. 3870/CT-CS on 10 June 2026, providing guidance on the implementation of obligations relating to Country-by-Country (CbC) Reports .
The guidance follows Vietnam’s accession to the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA) on 3 January 2025 and outlines the application of Country-by-Country Reporting (CbCR) requirements under the automatic exchange framework.
According to the letter, where an Ultimate Parent Entity (UPE) is located outside Vietnam and is required to file a CbC Report in its jurisdiction of residence, the report will be obtained by Vietnamese tax authorities through the Automatic Exchange of Information (AEOI) mechanism, provided that the jurisdiction has an activated CbC Report exchange relationship with Vietnam under the CbC MCAA.
The guidance further states that, in such cases, Vietnamese tax authorities will not accept CbC Reports submitted directly by taxpayers in paper form or through other manual submission methods. The measure is intended to align reporting procedures with Vietnam’s international commitments on the exchange of tax information.
An appendix to the letter lists 37 countries and territories that had established and activated effective CbC Report exchange relationships with Vietnam as of 17 April 2026. The jurisdictions include major trading partners such as China, Japan, South Korea, Singapore and Hong Kong (China), as well as several European countries including France, Germany, Italy, the United Kingdom, the Netherlands and Switzerland. Australia, India and Russia are also included.
For certain jurisdictions, including China, Croatia, Hong Kong (China), Latvia and the Russian Federation, the exchange relationships are effective for tax periods beginning on or after 1 January 2024.
The Department of Taxation has instructed local Tax Departments and specialised tax offices, including those responsible for e-commerce and large enterprises, to implement the guidance consistently across the country.
