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Vietnam Activates Bilateral CbCR Exchange Mechanism With 37 Jurisdictions

June 17, 2026

Following the participation of Vietnam authority in Multilateral Competent Authority Agreement (MCAA) regarding the exchange of Country-by-country Profitability reports (CbCR), the Department of Taxation has recently issued Official Letter No. 3870/CT-CS as of 10 June 2026 to confirm the participation toward bilateral exchange mechanism with several jurisdictions. The participation in MCAA reflects the commitment of Vietnam in sharing tax information across 37 jurisdictions and further serves assessment of Transfer pricing and Global Minimum Tax.

A. Changes in Tax Administration

• The Vietnamese Tax Authority can now directly access CbCR information through international automatic exchange platforms and will no longer accept paper-based reports or other manual direct submission from taxpayers.

B. Impact on Businesses

• Filing and compliance maintenance requirements for CbCR have been reduced for applicable enterprises.

• Support stronger Transfer Pricing management and facilitates the implementation of the Global Minimum Tax (Pillar Two).

C. Outlook and recommendations

• Continue to comply with global tax environment, as more bilateral exchange mechanisms could be expected to be implemented in the future.
• Multinational Enterprises (MNEs) will shift their focus from pure local filing to jurisdiction-mapping and governance, review to ensure consistency of their CbCR, jurisdictional transfer pricing documentation, and tax return positions.

Vietnamese taxpayers whose Ultimate parent companies are located under the listed jurisdictions in the Official Letter are recommended to:

• Obtain and maintain a Notification letter regarding the submission of CbCR in home jurisdiction as evidence such submission from the Group.

• Obtain and maintain the Vietnamese section of CbCR, as such context would be necessary for reconciliation and declaration of Pillar Two compliance in Vietnam.

37 listed jurisdictions:

The following 37 jurisdictions have agreed to activate MCAA with Vietnamese authority in exchanging CbCR:

1. Australia	20. Latvia
2. Austria	21. Luxembourg
3. Belgium	22. Malaysia
4. Bulgaria	23. Malta
5. China	24. The Netherlands
6. Croatia	25. Norway
7. Czech Republic	26. Peru
8. Denmark	27. Poland
9. Estonia	28. Portugal
10. France	29. Russia
11. Germany	30. Singapore
12. Greece	31. Slovakia
13. Hong Kong	32. Slovenia
14. Iceland	33. Spain
15. India	34. Sweeden
16. Ireland	35. Switzerland
17. Italia	36. Thailand
18. Japan	37. The United Kingdom
19. Korea