Circular 45 guiding the application for the Advance Pricing Agreement on tax administration
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Circular 45 guiding the application for APA
On 18 June 2021, the Ministry of Finance issued Circular 45/2021/TT-BTC (“Circular 45”) providing guidance on the implementation of Article 41 of Decree 126/2020/ND-CP (“Decree 126”) dated 19 October 2020 of the Government on the application of the Advance Pricing Agreement (“APA”) on tax administration for companies having transactions with their related parties. Other contents of the APA mechanism are implemented in accordance with the provisions of the Law on Tax Administration 38/2019/QH14 (“Law on Tax Administration”) dated 13 June 2019, Decree 132/2020/ND-CP (“Decree 132”) dated 05 November 2020 of the Government on tax administration for companies having transactions with their related parties, and other relevant legal documents.
This Circular takes effect from 03 August 2021 and replace Circular 201. Official APA application submitted but not concluded and having covered period not ended before the implementation of this Circular, shall continue to be resolved in accordance with the Law on Tax Administration, Decree 126, and this Circular.
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