Determining deducted loan interest cost of Enterprises engaged in transfer pricing
On June 26th 2018, Hanoi Department of Tax issued the Official dispatch No 43767/CT-TTHT. According to this dispatch, if Enterprises has transfer pricing transaction and this transaction arising from independent parties, the loan interest cost – which was used to calculated Corporate Income Tax – shall be determined as guidance in Clause 3 Article 8 in Decree No 20/2017/NĐ-CP. More specifically, the loan interest cost calculated by above provision is the total loan interest arising within a specified period (no distinguish the loan interest cost arising from related parties or independent parties).
