In-depth training: Transfer pricing & Global minimum Tax Risk management

Key Issues Businesses Should Review for the 2026 Tax Year

Transfer Pricing (TP) and Global Minimum Tax (GMT) are creating new requirements for tax management, particularly for businesses with related-party transactions and multinational groups.

In Vietnam, Decree No. 255/2026/ND-CP, effective from 1 July 2026, replaces Decree No. 132/2020/ND-CP and introduces a number of important changes relating to related-party relationships, related-party transaction disclosures, transfer pricing documentation and Country-by-Country Reporting (CbCR).

Meanwhile, GMT, under Pillar Two of the international tax reform framework, places increasing demands on the management of data, profits and taxes paid, as well as the ability to determine and substantiate the Effective Tax Rate (ETR).

Importantly, TP and GMT should not be viewed as two separate tax matters. Pricing policies, accounting and financial data, tax information and group reporting need to be managed consistently to enable businesses to proactively identify and manage potential risks.

To help businesses review key issues for the 2026 tax year, KTC Audit Company Limited is pleased to present the following in-depth training program:

TRANSFER PRICING & GLOBAL MINIMUM TAX RISK MANAGEMENT

KEY PROGRAM HIGHLIGHTS

01. TP & GMT – One Integrated Tax Management Perspective

Explore the key intersections between Transfer Pricing, Corporate Income Tax and Global Minimum Tax, with a focus on how related-party transaction data, profits and taxes paid may affect the determination of ETR under Pillar Two.

02. Decree No. 255/2026/ND-CP – What Should Businesses Review?

The program will focus on key areas requiring attention for the 2026 tax year, including:

• Regulations on related-party relationships, including cases involving the borrowing and lending of funds and assets;
• Requirements relating to EUR 750 million global consolidated revenue and CbCR;
• Cases eligible for exemption from related-party transaction declarations and transfer pricing documentation;
• Regulations on deductible interest expenses and the 30% EBITDA limitation;
• Key considerations when reviewing existing transfer pricing policies and documentation.

03. Data & Documentation Management – From Compliance to Risk Control

Practical discussion on Local File, Master File and CbCR; related-party transaction data; functional, asset and risk analysis; and consistency across Tax – Finance – Accounting – Group Reporting.

04. Case Discussion & Q&A

Review practical cases involving FDI businesses and multinational groups, with direct discussion with the speakers on issues businesses are currently facing.

WHAT BUSINESSES CAN TAKE AWAY

Participants will be able to:

• Review key changes introduced by Decree No. 255/2026/ND-CP;
• Assess the readiness of their transfer pricing policies, documentation and data;
• Identify key intersections between Transfer Pricing – Corporate Income Tax – Global Minimum Tax;
• Identify data areas requiring coordination across Tax – Finance – Accounting;
• Proactively identify issues that may develop into risks during tax audits, inspections and tax authority inquiries.

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.

DON’T JUST KEEP UP WITH REGULATIONS – TAKE CONTROL OF TAX RISKS

KTC cordially invites businesses and corporate professionals to join the program to gain regulatory updates, discuss practical cases with experienced specialists and identify key areas requiring attention for the 2026 tax year.