The country-by-country report (CbCR) is the most ‘global’ tier of transfer pricing documentation: one table showing, for each country where the group operates, its revenue, profit, tax paid and people. Vietnam’s rules on who files locally — and when — became considerably more detailed under Decree 255/2026/ND-CP.
Who is in scope
CbCR applies at group level: it concerns multinational groups whose ultimate parent’s consolidated revenue reaches the international threshold, carried into Vietnamese rules at paragraph 1 of Article 19 of Decree 255/2026/ND-CP, at a consolidated global revenue equivalent to 750 million euros for the fiscal year immediately preceding the reporting year, applied from 1 July 2026, replacing the VND 18,000 billion threshold in Decree 132/2020/ND-CP (expired on 1 July 2026). A Vietnamese subsidiary itself does not decide in the abstract: if the ultimate parent is abroad and its home country has an activated automatic CbCR exchange relationship with Vietnam, the report is filed by the parent at home and received by Vietnam through exchange — under the 2026 guidance, Vietnam does not then take a duplicate local filing from the Vietnamese taxpayer for groups in the activated exchange perimeter. Local filing in Vietnam arises in defined cases: a Vietnamese ultimate parent, or a foreign parent’s jurisdiction that does not exchange with Vietnam, with designation of one Vietnamese entity to file for the group members here.
Deadline and notification duties
The filing deadline — active, not on request — is within 12 months after the end of the ultimate parent’s fiscal year, in the encrypted XML format and through the channel Decree 255/2026/ND-CP prescribes. Alongside the report itself sit notification duties: the group must identify which entity files the CbCR and in which country, within the statutory notification windows, so the Vietnamese authority knows whether to expect an exchange or a local filing. A 2026 tax authority guidance letter (Official Letter 3870/CT-CS) clarified that automatic exchange is activated but currently operates one way — from Vietnam outward — and lists the partner jurisdictions within the exchange perimeter; groups should test their parent jurisdiction against that list before assuming no Vietnamese step is needed.
Missing the report: penalties and the signal it sends
Failure to file or notify draws administrative penalties for tax reporting breaches under current tax administration law (the Law on Tax Administration 108/2025/QH15 framework). The larger cost is reputational within the audit system: CbCR data is precisely what exchange mechanisms deliver to Vietnam about groups that did not file locally, so a gap is discoverable rather than concealable — and a discoverable gap in the most standardised OECD report reads as a compliance attitude signal when audit cases are selected. For Vietnamese subsidiaries, the practical duty is annual: confirm the parent’s filing channel, keep the notification evidence, and file locally the moment the group’s facts fall outside the exchange perimeter.
Frequently Asked Questions
Which enterprises must file a country-by-country report (CbCR)?
Vietnamese members of multinational groups whose ultimate parent’s consolidated revenue reaches the CbCR threshold (under paragraph 1 of Article 19 of Decree 255/2026/ND-CP: consolidated global revenue equivalent to 750 million euros for the fiscal year immediately preceding the reporting year, applied from 1 July 2026; the VND 18,000 billion level in Decree 132/2020/ND-CP expired on 1 July 2026), through one of two channels: the ultimate parent files at home and the report is exchanged, or a Vietnamese entity files locally where no exchange mechanism operates.
What is the filing deadline?
Within 12 months after the end of the ultimate parent’s fiscal year. Groups must also complete the related notification steps identifying which entity files and where, under the mechanism detailed in Decree 255/2026/ND-CP.
What are the penalties for not filing?
Administrative penalties for reporting breaches under tax administration rules, plus a worse audit profile: a missing CbCR is easily discovered through international exchange channels the authority participates in, and discovery without disclosure is treated as a compliance attitude signal.
This article has been quality-reviewed by the FLAW AI Legal Council