Asia Transfer Pricing Brief Highlights Q2 2026 Updates in UAE, Singapore, and Vietnam

In its Q2 2026 transfer pricing brief, professional services firm Dezan Shira & Associates reported that tax authorities across Asia and the Middle East introduced significant regulatory updates affecting multinational enterprises and related-party transactions.

On June 22, 2026, the UAE issued Ministerial Decision No. 96 of 2026, which formally adopts the latest OECD interpretive materials for the UAE's Qualified Domestic Minimum Top-up Tax (QDMTT) regime under Cabinet Decision No. 142 of 2024. The decision incorporates the OECD's January 2026 Side-by-Side package, including the Substance-Based Tax Incentive Safe Harbour, applies to fiscal years beginning on or after January 1, 2025, and repeals Ministerial Decision No. 88 of 2025.

In Singapore, the Inland Revenue Authority of Singapore (IRAS) released the ninth edition of its Transfer Pricing Guidelines on June 4, 2026. The publication provides new guidance on the treatment of share-based compensation costs under the Transactional Net Margin Method for intercompany service transactions, taking effect from Year of Assessment 2026.

Additionally, the Government of Vietnam enacted Decree No. 255/2026/ND-CP on June 30, 2026, effective July 1, 2026. The new decree replaces Decree No. 132/2020/ND-CP and Decree No. 20/2025/ND-CP, raising the revenue exemption threshold for preparing transfer pricing documentation from VND 200 billion to below VND 500 billion and removing the 'simple functions' criterion.