In practice, interest-free loans are often used by businesses as a flexible tool to support internal cash flow, assist employees, or provide relief to partners. However, from a tax management perspective, this is one of the transactions most likely to come under scrutiny due to violations of the arm\u2019s-length principle.<\/p>\n
Without a reasonable explanation, an interest-free loan may cause the tax authorities to assess financial revenue, adjust expenses, and collect back taxes. For related parties, the risks are even more stringent under Decree 255\/2026\/ND-CP<\/a><\/strong>. The Decree takes effect on July 1, 2026, applies to the 2026 corporate income tax filing period, and replaces Decree No. 132\/2020\/ND-CP and Decree No. 20\/2025\/ND-CP.<\/p>\n The most notable aspect of this topic: for the first time, the borrow, lend<\/strong> A relationship between a business and an individual who manages or controls it (or their relatives) is identified as the basis for the existence of an affiliated relationship.<\/p>\n