Legal News

[Taxation] Official Letter from the Directorate General of Taxation on the status of filing Country-by-Country Reports (CbCR)

2024/08/15

On July 29, 2024, the GDT sent Official Letter No. 3279/TCT-CS to tax bureaus of regions and municipalities directly under the Central Government requesting information on the status of submission of the Country-by-Country Report (CbCR) of enterprises for the period from 2020 to 2022. For enterprises that have submitted country-by-country reports, the Regional Tax Department will send hard copies and electronic scanned copies of the submitted documents to the Directorate General of Taxation. For enterprises that have not submitted, the regional tax bureau will prepare a list of those enterprises and report it to the DGT, specifying the reasons for not submitting the documents.

Decree No. 132/2020/ND-CP on Tax Administration for Enterprises Engaged in Related Transactions, which came into effect in 2020, provides guidelines regarding the obligation to prepare country-specific reports. However, many issues and uncertainties remain in practice.

Although this move by the GDT is intended to provide a comprehensive assessment of implementation, it is possible that in the future the GDT will issue detailed guidance or official letters to enterprises that have difficulty determining whether or not they are required to file country-by-country reports. As soon as the latest information is provided by the DGT, it will be announced in future Legal News.

 

References:
Official Letter No. 3279/TCT-CS of GDT
Decree No. 132/2020/ND-CP