The cost of consulting services for related-party transactions is becoming a top concern for FDI businesses and multinational corporations amid pressure to tighten transfer pricing regulations. Decree 132/2020/ND-CP, This article provides an in-depth perspective from tax consulting practice, drawing on Decree 20/2025/ND-CP amending and supplementing Decree 132 and OECD international tax policies on related-party transactions.
- Get the latest market rates for related party transaction advisory services.
- Analyzing the factors that determine costs
- Warning: Serious legal risks when choosing cheap services.
This helps businesses balance their budgets effectively, comply with regulations, and build a solid record of related-party transactions before tax audits.
The strategic importance businesses receive from the cost of advising on related-party transactions.
Understanding the true nature of these fees will help businesses shift from a passive to an active approach to controlling financial risks. To understand why these are considered an investment in asset protection rather than just operating expenses, join MAN – Master Accountant Network in an in-depth analysis of the latest legal hurdles and the direct consequences of lacking consultation from related-party transactions experts.
Strict legal basis from Decree 132/2020/ND-CP and Decree 20/2025/ND-CP
Decree 132/2020/ND-CP clearly stipulates tax management for enterprises with related-party transactions. By 2026, tax authorities in Ho Chi Minh City have thoroughly implemented post-audit measures based on big data analysis.
Related party transaction advisory fees It's not simply the cost of hiring someone to prepare the report, but the cost of purchasing legal assurance. According to regulations:
- Interest expense limitation: The total interest expense deductible when determining corporate income tax must not exceed the net profit from business operations plus interest expense and depreciation expense (EBITDA).
- Arm's Length Principle: The price of transactions between related parties must be equivalent to the price of transactions between independent parties under comparable conditions.
Risks of lacking expert advice
If businesses handle related-party transaction consulting themselves or use low-quality services to save on consulting costs, the following risks may arise, not only in terms of documentation errors but also leading to severe financial penalties. Decree 125/2020/ND-CP:
- A fine of VND 8,000,000 to VND 25,000,000 will be imposed for failing to prepare documentation for determining transfer pricing or failing to submit the required appendices.
- Providing incomplete or false information may result in a fine of up to VND 20,000,000.
- Penalty for underreported tax (20%): If the lack of documentation leads to an incorrect declaration of tax payable, the business will be penalized under 20% for the amount of tax underreported.
- Penalties for tax evasion (1-3 times): If the tax authorities can prove that a business intentionally used transfer pricing to evade taxes, the penalty ranges from 1 to 3 times the amount of tax evaded.
- Late payment penalty (0.03%/day): This amount often accumulates significantly over inspection periods (usually 3-5 years), adding a considerable financial burden.
- Tax assessment: The tax authorities have the right to determine the price and profit margin if the documentation does not demonstrate objectivity. In such cases, businesses lose their autonomy regarding their own costs and profits.
- Exclusion of interest expense: Billions of VND in interest expense may be disallowed if it exceeds the 30% EBITDA threshold without a reasonable optimization plan or justification.
Required documents that incur related-party transaction advisory fees.
To determine the cost of related-party transaction advisory services, businesses need to know which types of documentation they are required to prepare. According to the BEPS (Benefit Erosion and Profit Shifting) standard, there are three main levels of documentation:
Local File
This is the most detailed record of the company's operations in Vietnam, including supply chain analysis, functional analysis, asset and risk analysis (FAR Analysis), and most importantly, related-party transactions that occurred during the year.
Master File
If a business belonging to a multinational corporation has consolidated total revenue exceeding a specified threshold, providing a Master File is mandatory so that the tax authorities can have a comprehensive view of the group's cash flow and profits.
Country-by-Country Profit Reporting
This is the most complex type of report, requiring coordination between the parent company and its subsidiaries globally. The cost of preparing this report is usually very high due to the sensitive nature of the data.
Appendixes to be included with the corporate income tax return.
This includes Appendices I, II, III, and IV. Misrepresentation of information in these appendices compared to actual records is a leading cause of tax audits.
What are the criteria for determining whether the cost of advising on related-party transactions is high or low?
The market reality reveals a clear differentiation in fees. Many businesses wonder why the fees charged by the Big4 firms (PwC, Deloitte, EY, KPMG) are often in the "million dollar" or billions of dong range, while domestic consulting firms only quote prices in the tens of millions of dong.
This disparity stems primarily from global brand value. For multinational corporations listed on international stock exchanges, utilizing services from the Big4 is a "card" guaranteeing credibility with global shareholders and partners, despite the extremely high operating costs due to their cumbersome structures.
However, for FDI corporations and businesses in Vietnam seeking budget-optimized solutions while ensuring absolute legal safety, these options are available. related party transaction advisory unit In Vietnam, professional and reputable firms include MAN – Master Accountant Network, ACCS, etc. Below are four core criteria that determine the cost of affiliate transaction consulting:
Transaction size and nature
A business that only engages in internal borrowing transactions will have significantly lower related-party transaction advisory fees compared to a business with complex transactions such as:
- Transfer of intangible assets (brand, technical know-how).
- Royalty fees, corporate management fees.
- Goods are bought and sold through multiple intermediaries.
Dedicated database access rights
This is the weapon of the consulting firms. To prove market value, experts must perform benchmarking. Renting or purchasing data from reputable organizations such as Moody's, Bureau van Dijk (Orbis/Tp-catalyst) costs tens of thousands of USD annually. The consulting fees for related-party transactions from reputable firms already include the allocation of this data licensing cost.
Functional, Asset, and Risk Analysis (FAR Analysis)
A quality report requires a deep understanding of the business's operations. Experts must directly interview production, warehousing, and sales departments to identify who holds the real risk. If the service simply sits back and compiles data, the price will be cheap, but the protection offered will be virtually nonexistent.
Experiences in dialogue with the Tax Authority
The value of an expert lies in their ability to provide explanations during inspections. Units with many years of experience in the Ho Chi Minh City market will know how to present documents in a way that aligns with the local tax authority's inspection perspective, helping businesses minimize the risk of being overcharged.
Referral agency advisory fees in Ho Chi Minh City in 2026
To help businesses gain a visual understanding of the cost of related-party transaction advisory services in Ho Chi Minh City in 2026, below is a summary table of popular service packages on the market. It reflects the average fees corresponding to different levels of document complexity, business size, and compliance requirements. This allows businesses to easily compare and choose a service package that suits their needs and budget.
| Type of service | Applicable objects | Estimated fee (VND) | Execution time |
| Review and Declaration Package Appendix | Small businesses with simple transactions (only borrowing capital). | 20,000,000 – 45,000,000 | 7-10 days |
| Create a Local File | Manufacturing and trading businesses frequently engage in internal buying and selling transactions. | 60,000,000 – 150,000,000 | 15-30 days |
| National Profile and Global Profile Combo | Businesses belonging to multinational corporations have parent companies located abroad. | 150,000,000 – 330,000,000 | 30-45 days |
| Search for comparative data (Benchmarking) | The company prepared the documentation itself but lacked data to prove the price. | 30,000,000 – 70,000,000 | 15 days |
| Support for explanation | The business is currently undergoing a tax audit or inspection. | Contact MAN – Master Accountant Network | According to the inspection schedule |
Note: The above is a table of average market fees in Ho Chi Minh City. It is for reference only; actual prices may vary depending on the transaction size. Contact Contact MAN – Master Accountant Network for detailed advice and pricing!
Warning: Risks when choosing low-cost (below-market price) services.
“"You get what you pay for" is always true in the field of tax consulting. When businesses choose a firm with surprisingly low fees for related-party transaction consulting, be wary of the following loopholes:
- Using misleading comparable businesses: Low-cost providers often use outdated or inconsistent data regarding industry and size. This results in immediate rejection of the application when the tax authorities cross-reference it against the industry data system.
- Ignoring the economic nature of the analysis: Decree 132 emphasizes that "substance determines form." If consultants do not understand the nature of the business and only prepare reports according to a template, they will not be able to explain why the enterprise is losing money while its affiliated party is making a profit.
- Disappearing during inspections: In many cases, consulting firms are reluctant to participate in direct briefings with inspection teams due to a lack of in-depth knowledge, leaving businesses to fend for themselves with challenging questions from tax officials.
- Errors in EBITDA calculation: With the update of Decree 20/2025, calculating EBITDA to determine the interest expense ceiling is very complex. Even a small error in the formula can completely change the amount of tax payable.
The benefits of investing appropriately in related-party transaction advisory fees.
Paying a reasonable fee for affiliate transaction advisory services to professional firms provides the following value:
- Optimizing cash flow: Related party transaction advisory services A reputable and professional approach will help businesses fully utilize regulations regarding the carryforward of interest and losses, and the offsetting of expenses between related parties in a legal manner.
- Complete peace of mind: The application is prepared based on a copyright database, is highly logical, and is unlikely to be rejected by authorities.
- Building credibility with regulatory authorities: A professional and well-presented portfolio is the best way for businesses to demonstrate compliance, thereby minimizing the frequency of periodic inspections.
Conclude
Investing in related-party transaction advisory services is an investment in business sustainability. In Ho Chi Minh City, price competition for advisory services is intense, but competition in quality and protection is what businesses should prioritize. Businesses need to carefully choose between the glamorous brands of international corporations and the efficiency and optimization of specialized domestic advisory firms to find the best financial solution.
Contact MAN – Master Accountant Network for free consultation and support!
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
- Email: man@man.net.vn
Content is moderated by: Mr. Le Hoang Tuyen – Founder & CEO of Man, CPA Vietnam Auditor with over 30 years of experience in Accounting, Auditing and Financial Consulting.
Frequently Asked Questions about Affiliate Market Advisory Fees
From the perspective of the Tax Authority, losses are often a sign of profit shifting abroad. Therefore, businesses incurring losses should consult related-party transaction advisory services to have experts demonstrate that the losses are due to objective factors (market conditions, initial investment costs) and not due to internal pricing that does not reflect market prices.
It is entirely possible. However, the biggest challenge is access to copyrighted comparative databases (approved by the tax authorities) and experience in handling complex FAR situations. Making mistakes on your own often results in penalties many times greater than the consulting fee.
Yes. These are expenses related to business operations and compliance with the law, and therefore can be deducted when calculating corporate income tax if there are complete and valid invoices and supporting documents.
Yes. Related party transaction records must be updated annually due to: Changes in business results, Changes in related party transactions, and Updates to market comparison data.
MAN accompanies businesses throughout this process. A dedicated team will protect records during inspections, including: explaining matters to tax authorities, preparing supplementary documents, and participating directly in the inspections.Why do loss-making businesses still have to file related-party transaction records?
Can businesses prepare their own documentation to save costs?
Are consulting fees for related-party transactions considered deductible expenses?
If I've already submitted my application, do I need to do it again next year?
When facing a tax audit, does the consulting firm provide support?