In-Depth Training: Managing Risks in Related-Party Transactions & The Global Minimum Tax

Updates on Law on Tax Administration No. 108, Decree No. 255/2026/ND-CP & Decree No. 236/2025/ND-CP – Practical Filing Guidance & Tax Audit Defense Skills

Tax management and compliance are placing increasingly stringent and specific demands on multinational corporations and enterprises engaged in related-party transactions.

For the 2026 tax year, businesses must pay particular attention to Global Minimum Tax (GMT) compliance under Resolution No. 107/2023/QH15 and Decree No. 236/2025/ND-CP, alongside new transfer pricing regulations introduced under the Law on Tax Administration No. 108/2025/QH15 and Decree No. 255/2026/ND-CP.

These changes extend far beyond basic tax liability determination—they demand rigorous data preparation, precise tax return filings, accurate related-party identification, and proactive management during tax audits and inspections.

To assist enterprises in updating key regulations, ensuring statutory compliance, and mastering practical handling of emerging challenges, KTC Auditing Company Limited is pleased to present our in-depth training program:

MANAGING RISKS IN RELATED-PARTY TRANSACTIONS & THE GLOBAL MINIMUM TAX

PROGRAM AGENDA

I. Guidance on Global Minimum Tax (GMT) Compliance

(Pursuant to Resolution No. 107/2023/QH15 & Decree No. 236/2025/ND-CP)

1. Core principles of Top-up Corporate Income Tax under the Global Anti-Base Erosion (GloBE) Rules
2. Practical filing procedures for Top-up Corporate Income Tax

II. Updates on Law on Tax Administration No. 108/2025/QH15 & Decree No. 255/2026/ND-CP on Related-Party Transactions

1. Key provisions under the Law on Tax Administration No. 108/2025/QH15 directly impacting transfer pricing determination obligations
2. Four critical focus areas under Decree No. 255/2026/ND-CP:
   • Criteria for identifying related-party relationships
   • Principles for selecting transfer pricing methodologies aligned with economic substance
   • Standards and benchmark criteria for selecting independent comparables
   • Limitations on deductible net interest expense for Corporate Income Tax purposes

III. Practical Guidance on Preparing & Filing Appendix I under Decree No. 255/2026/ND-CP

IV. Common Reporting Pitfalls & Tax Audit Defense and Explanation Skills

V. Real-world Case Studies & Interactive Expert Q&A

KEY TAKEAWAYS

Upon completing the program, participants will be able to:

• Master Regulatory Shifts: Gain an authoritative grasp of the latest GMT compliance rules and landmark changes under Law No. 108/2025/QH15 and Decree No. 255/2026/ND-CP.
• Standardize Related-Party Identification: Confidently identify related parties, apply optimal transfer pricing methodologies, and establish robust comparative datasets.
• Master Filing Techniques: Seamlessly organize required data and accurately complete Appendix I pursuant to Decree No. 255/2026/ND-CP.
• Enhance Expense Defensibility: Promptly detect non-deductible net interest risks and establish structured substantiation for tax audits and inspections.
• Implement Practical Solutions: Directly apply the templates, frameworks, and case study insights into internal corporate tax governance.

FEATURED SPEAKERS

Ms. Nguyen Thi Hanh – Tax & Transfer Pricing Specialist

Over 30 years of experience in Tax, including 20 years directly involved in tax inspection and audit activities. She previously served as Deputy Director General and Deputy Head of the Reform and Modernization Board of the General Department of Taxation, and has extensive experience in professional training and technical support relating to related-party transactions and transfer pricing.

Ms. Thai Thi Van Anh (FCCA, CPA Vietnam) – Partner, KTC Audit Company Limited

Over 25 years of experience in audit, accounting and tax advisory, supporting businesses in financial management, compliance and practical accounting and tax matters.

Proactive Compliance & Strategic Tax Risk Management

KTC cordially invites your enterprise to join our industry leaders to update pivotal regulations, resolve real-world challenges, and ensure optimal tax preparedness for the 2026 tax year.

📞 Direct Support: 0904 821 889

✉️ Email: khiem.trong.nguyen@ktcvietnam.com