International Earnings Reporting Consulting Services: Solutions for Compliance with the Latest Regulations 2026

Country-Based Income Reporting Advisory (CbCR) services This is becoming an urgent need for businesses with affiliated relationships, especially multinational corporations and businesses with ultimate parent companies abroad, as Decree 255/2026/ND-CP Official changes have been made to a series of regulations regarding revenue thresholds, exchange rates, submission formats, and deadlines for submitting the CbCR report. On July 9, 2026, the Tax Department issued Official Letter 4697/CT-CS of 2026 introducing 10 New points of Decree 255/2026/ND-CP, in which the content regarding the Country-by-Country Report (Article 19) is one of the biggest changes, directly impacting the reporting obligations of businesses.

The problem is that many businesses are still applying the revenue threshold, format, and deadline for submitting the Country-by-Country Profit and Cost (CbCR) report according to the old Decree 20/2025/ND-CP, while the new regulations have fundamentally changed how this obligation is determined. Without timely updating, businesses may submit the report at the wrong threshold, in the wrong format, or late, leading to the risk of administrative penalties for tax violations. This is why consulting on Country-by-Country Profit and Cost (CbCR) reporting in accordance with Decree 255/2026/ND-CP is crucial for businesses to implement now.

This article will help you understand the most important changes related to the CbCR Report, and why using cross-border earnings reporting consulting services at this stage is crucial for your business's legal safety.

What is a cross-border earnings reporting advisory service?

The Country-by-Country Profit Reporting (CbCR) consulting service is a specialized tax consulting service provided by a team of experts knowledgeable in related-party transactions law. Its purpose is to assist businesses in correctly identifying their obligations, preparing, and submitting the CbCR report in accordance with Article 19 of Decree 255/2026/ND-CP.

Specifically, this service helps businesses determine global consolidated revenue thresholds, exchange rates, reporting formats, deadlines for submitting the Notice of Contributors to the CbCR, and review cases that are exempt from or required to submit reports in Vietnam.

Legal basis for related-party transactions according to current regulations.

Decree 255/2026/ND-CP is a document regulating tax management for related-party transactions of enterprises with related-party relationships. It is built upon and amends many provisions of the previous Decree 20/2025/ND-CP. 

Notably, a number of regulations in Decree 255/2026/ND-CP are directly referenced to the 2025 Law on Tax Administration, specifically the principles of application in tax administration (Clause 4, Article 6), the principles of tax inspection (Clause 1, Article 22), the rights and obligations of taxpayers (Article 37), as well as regulations on the tax authority's database (Clause 2, Article 35 of the 2025 Law on Tax Administration).

The entities directly affected by Decree 255/2026/ND-CP are enterprises with related-party relationships as defined in Article 5 of the Decree, including enterprises with parent companies, subsidiaries, and branches both domestically and internationally, or those engaging in lending, borrowing, or lending transactions with related individuals or organizations. Given this broad scope of impact, a correct and thorough understanding and accurate application of the new regulations is a prerequisite for businesses to avoid errors in tax declarations.

Significant changes to the Country-by-Country Report (CbCR)

This is the content category that has undergone the most changes, including:

• The global consolidated revenue threshold for determining the obligation to prepare the CbCR report is now based on revenue from the fiscal year immediately preceding the reporting year, instead of revenue for the tax period as before.
• The revenue threshold for preparing the CbCR report has been revised to the equivalent of 750 million Euros, instead of the previous 18,000 billion VND, to align with exchange rate fluctuations and OECD guidance in BEPS Action 13.
• The regulation stipulates a unified exchange rate based on the central exchange rate or the average cross-exchange rate for December as published by the State Bank of Vietnam.
• To supplement and clarify cases where the CbCR Report does not need to be submitted in Vietnam, including cases where the Report has been automatically exchanged under an Agreement with the competent authority, cases where an organization submits the report on behalf of the applicant, or due to differences in revenue thresholds or currency exchange rates between countries.
• Additional cases where submitting the CbCR report in Vietnam is mandatory include situations where the ultimate parent company is not obligated to prepare the report in its country of residence, or when the conditions for applying for a reporting agency to submit the report on its behalf are not met.
• The regulations are supplemented to require submission of reports in encrypted XML format, submitted through the Tax Management Information System in accordance with the standards of BEPS Action 13.
• The deadline for submitting the CbCR Report is no later than 12 months from the end of the fiscal year of the ultimate parent company. Furthermore, the Decree promulgates the Notification Form on the Entities Required to Submit the CbCR Report (Form No. 01/TB-BCLN), which only needs to be submitted once when the obligation arises for the first time, and must be updated within 90 days if there are any changes to the information.

With such a large volume of changes, having a consulting service specializing in Decree 255 to review each timeline and form is almost mandatory for multinational corporations and businesses with parent companies abroad.

Raise the threshold for exemption from preparing Transfer Pricing Documentation.

Previously, to be exempt from preparing Transfer Pricing Documentation, businesses had to meet four criteria simultaneously, including the requirement of "operating with simple functions" and a revenue threshold of under 200 billion VND.

Decree 255/2026/ND-CP raised the revenue threshold to below VND 500 billion and completely removed the criterion of "simple functions". This is a beneficial change, significantly expanding the group of low-risk businesses exempt from the obligation to prepare documentation, helping to reduce compliance costs.

Responsibilities and powers of the tax authority

The decree adds very important regulations:

Tax authorities are not permitted to use taxpayers' CbCR reports to adjust or determine the price of related-party transactions, but only for risk management and information exchange in accordance with international commitments.

In addition, the Decree supplements regulations on the responsibility to support voluntary compliance, reflecting a shift in the tax management model from purely "risk management" to "compliance management and compliance support," with taxpayers at the center.

Transitional provisions regarding interest expense

Businesses eligible for the carryforward of interest expense provisions under Article 3 of Decree 20/2025/ND-CP will continue to be subject to the carryforward for the remaining period under the old regulations. This is a crucial point ensuring the rights of businesses during the policy transition period. 

Reference: How to calculate interest expense according to Decree 255.

Summary table comparing the old and new regulations regarding CbCR reporting.

To help businesses better understand the extent of the changes, here is a brief summary of the core differences between the old regulations (Decree 20/2025/ND-CP) and the new regulations (Decree 255/2026/ND-CP):

Looking at the comparison table above, it's clear that changes in revenue thresholds, exchange rates, and CbCR reporting formats are the most complex aspects, requiring businesses to seek professional support from a CbCR consulting firm to ensure accurate implementation from the outset. 

Why should businesses use cross-border earnings reporting consulting services?

It should be noted that Decree 255/2026/ND-CP will be applied immediately from the 2026 corporate income tax period. This means that all CbCR reports related to the 2026 fiscal year of the ultimate parent company must have their thresholds determined, exchange rates converted, and be prepared and submitted in accordance with the new regulations mentioned above, instead of applying Decree 20/2025/ND-CP as before. With limited time remaining to prepare for the 2026 corporate income tax settlement period, businesses need to proactively use CbCR consulting services early to avoid being caught off guard when the reporting deadline arrives. 

Risks if businesses implement regulations independently without staying updated.

If businesses continue to apply the old revenue threshold (VND 18,000 billion) instead of the equivalent of €750 million as stipulated in the new regulations, or fail to update the XML format when submitting the CbCR report through the Tax Management Information System, they may submit reports in the wrong format or on the wrong deadline, leading to administrative penalties for tax violations. Furthermore, omitting loan and lending transactions involving individual executives, and the new additions in Article 5, could also cause businesses to underdeclare related party relationships. 

Comparing the risks of doing it yourself and the benefits of using a multinational earnings reporting advisory service.

To better illustrate the difference between handling things yourself and having experts on hand, here is a brief comparison of the risks businesses may face if they try to implement the new regulations themselves, and the specific benefits of using CbCR's consulting services for each task: 

As can be seen, most of the aforementioned risks stem from a lack of timely updates on the new provisions of Decree 255/2026/ND-CP on CbCR Reporting, while the benefits of CbCR consulting services extend beyond simply avoiding errors; they also help businesses proactively fulfill their obligations within the scope of the law. This is the foundation for businesses to consider choosing a competent consulting firm to accompany them throughout the compliance process. 

What does a country-wide earnings reporting advisory service include?

Related party transaction advisory services A comprehensive and in-depth MAN – Master Accountant Network typically includes the following categories:

Consulting on identifying relationships and obligations for preparing the CbCR Report.

Review global consolidated revenue, determine the equivalent threshold of 750 million Euros, and determine the fiscal year based on the exchange rate in accordance with Article 19 of Decree 255/2026/ND-CP. 

Providing advice on preparing and submitting CbCR reports in the correct format and on time. 

Assist in preparing reports in encrypted XML format, submitting them through the Tax Management Information System, ensuring a deadline of no later than 12 months from the end of the fiscal year of the ultimate parent company. 

Consulting services for preparing and submitting Country-by-Country Reports (CbCR).

Determine the revenue threshold, exchange rate, submission deadline, and XML format as stipulated in Article 19, as well as prepare the Notification of Entities Submitting the CbCR Report in the correct format and within the specified deadline.

Consultation on preparing the Notice regarding the entities required to submit the CBCR Report. 

Support in preparing and submitting Form No. 01/TB-BCLN correctly, on time, and updating information within 90 days when changes occur.

Consulting on identifying affiliations and related obligations. 

Review the entire ownership structure and all borrowing, lending, and lending transactions to accurately determine whether the enterprise falls under the scope of Decree 255/2026/ND-CP, and assist in preparing Transfer Pricing Documentation when necessary. 

Representing the company and providing explanations to tax authorities when required.

Supporting businesses during tax audits and inspections related to transfer pricing, ensuring that the legitimate rights of businesses are properly protected in accordance with Article 37 of the 2025 Tax Administration Law.

Who needs cross-country earnings reporting consulting services?

Not all businesses are required to prepare a CbCR report; therefore, CbCR consulting services are particularly necessary for the following groups of businesses: 

• Businesses belonging to multinational corporations have consolidated global revenues equivalent to 750 million Euros or more.
• Businesses with a parent company located abroad need to clearly identify cases where they are exempt from or required to submit the CbCR report in Vietnam.
• The enterprise is designated by the parent company to submit the CbCR report on its behalf.
• Businesses with parent companies, subsidiaries, and affiliated branches both domestically and internationally engage in borrowing, lending, and lending transactions with individuals and organizations that have affiliated relationships.
• The company is currently in the process of applying the transitional provisions regarding interest expense under Decree 20/2025/ND-CP.

Reference price list for cross-country earnings report consulting services in 2026.

The cost of CbCR consulting services depends on the size of the corporation, the number of members whose reports need to be consolidated, and the complexity of the related documentation (National Documents, Global Documents, CbCR Reports). Below is a reference price list, designed to be competitive in the market, to help businesses easily choose a suitable package: 

Note: The prices listed above are for initial reference only, are competitively priced, and may vary depending on the scale and complexity of each business. For an accurate quote on CbCR consulting services tailored to your specific situation, please contact us directly for a free survey and consultation. 

Conclude

Decree 255/2026/ND-CP introduces several significant changes regarding the reporting of cross-country profits, from revenue thresholds, exchange rates, submission formats, to cases of exemption and mandatory reporting. These changes directly impact the tax obligations and legal risks of related-party enterprises in 2026. 

Proactively reviewing and preparing documentation now will help businesses avoid unnecessary risks. Our team of related-party transaction experts is ready to work with businesses in identifying obligations, standardizing documentation, and ensuring full compliance with the latest regulations in Decree 255/2026/ND-CP. 

Contact MAN – Master Accountant Network To receive a free review and consultation regarding your company's related-party transaction compliance status.

Contact information MAN – Master Accountant Network

• Address: No. 19A, Street 43, Tan Thuan Ward, Ho Chi Minh City
• Mobile/Zalo: 0903 963 163 – 0903 428 622
• E-mail: man@man.net.vn
• Google Business Profile: View MAN – Master Accountant Network's Google Business Profile 
• LinkedIn Founder: View expert Le Hoang Tuyen's LinkedIn profile. 

Responsible for production and professional content review by: Mr. Le Hoang Tuyen – Founder & CEO of MAN – Master Accountant Network. He is a CPA Vietnam auditor with over 30 years of in-depth experience in accounting, auditing, taxation, and corporate legal consulting.

Frequently Asked Questions about International Earnings Reporting Advisory Services

Which businesses are required to submit a Country-by-Country Report in Vietnam according to Decree 255?

According to Article 19 of Decree 255/2026/ND-CP, enterprises in Vietnam must submit the CbCR report when the ultimate parent company has consolidated global revenue equivalent to 750 million Euros or more (based on the fiscal year immediately preceding the reporting year), except in cases where the report has been automatically exchanged with the Vietnamese tax authorities or another organization has been designated to submit the report on its behalf. Furthermore, this obligation also arises when the ultimate parent company is not obligated to prepare the report in its country of residence, or when it does not meet the conditions for applying the mechanism of having an organization submit the report on its behalf. 

What is the revenue threshold for determining the obligation to prepare the 2026 CbCR report?

According to the new regulations in Article 19 of Decree 255/2026/ND-CP, the threshold for consolidated global revenue to determine the obligation to prepare the CbCR Report is the equivalent of 750 million Euros, converted using the central exchange rate or the average cross-exchange rate for December published by the State Bank of Vietnam, instead of the fixed amount of 18,000 billion VND as stipulated in the old regulations.

What is the deadline for submitting the CbCR Report and the date for notifying the entities required to submit the CbCR Report?

According to Article 19 of Decree 255/2026/ND-CP, the CbCR Report must be submitted no later than 12 months from the end of the fiscal year of the ultimate parent company of the reporting year. The Notification of Entities Required to Submit the CbCR Report (Form No. 01/TB-BCLN) only needs to be submitted once when the obligation first arises, no later than the end of the fiscal year of the ultimate parent company; if there are any changes to the information, the enterprise must update it within 90 days from the date of the change. 

Which agency has the authority to use a taxpayer's Country-by-Country Report for risk management purposes? 

According to Article 21 of Decree 255/2026/ND-CP, tax authorities have the right to manage and use taxpayers' country-by-country profit reports for risk management and information exchange purposes in accordance with Vietnam's commitments under international tax agreements, but they may not use them to adjust or determine the price of related-party transactions.