The cost of preparing Transfer of Interest Documentation (LIA) in 2026 is becoming a major concern for many businesses with related-party transactions, especially in the context of tax authorities intensifying transfer pricing audits using AI and international data. Many businesses wonder whether the fees, ranging from tens to hundreds of millions of VND, are a burden or actually an investment to mitigate the risks of tax arrears, penalties, and profit assessment. This article will provide a comprehensive analysis of the legal basis, cost components, and a reference price list for different business sizes, while also highlighting the significant risks involved if businesses attempt to prepare LIA in-house or invest insufficiently in the process.
Legal basis and mandatory nature in 2026
Before exploring the costs of preparing a Related Party Transaction Document, businesses need to understand their legal obligations. Currently, the highest legal framework governing this issue is... Decree 132/2020/ND-CP.
Decree 132/2020/ND-CP regulating related-party transactions
Decree 132/2020/ND-CP is currently the most important legal document regulating tax management for businesses with related-party transactions. Here are some points that businesses need to be aware of:
Expand the scope of linked objects.
- The regulations clearly define relationships considered as "associates," such as: one party holding at least 25% of contributed capital; one party lending at least 25% of contributed capital to the other party; and accounting for over 50% of total medium and long-term debt.
- Family relationships (spouse, parents, children, etc.) that run the business are also under scrutiny.
Control interest expense 30% EBITDA
- This is the hottest topic: The total deductible interest expense when determining corporate income tax must not exceed the net profit from business operations plus interest expense and depreciation expense (EBITDA).
- Any interest expense exceeding the amount covered by 30% will be carried forward to the next tax period (for a maximum of 5 years).
The principle "Substance determines form"“
The tax authorities have the right to reject transactions that are not of an economic nature or are created for the purpose of tax avoidance. Transaction prices must be determined according to market price principles (Arm's length).
The tax authority has the power to determine taxes.
If a business fails to provide, provides incomplete, or its records lack objectivity, the tax authorities have the right to determine the profit margin based on the comparative data they possess.
The latest updates for the period 2025-2026.
By 2026, tax authorities will not only check the formal completeness of transactions but also delve into their economic nature. Errors such as missing comparable data or inappropriate pricing methods will be severely punished. Understanding the costs of preparing related-party transaction documentation in advance is key for businesses to be proactive in all situations.
In summary, these points explain why the cost of preparing a Related Party Transaction Documentation becomes a mandatory investment to protect businesses from the risk of tax arrears and to exclude interest expense deductions.
Factors that make up the cost of preparing a Related Party Transaction Document.

Why do some companies quote prices as low as a few million dong while others quote hundreds of millions? The cost of preparing a related-party transaction document is not a fixed figure but is composed of three core elements:
Cost of comparative data (Benchmarking Study)
This is the "heart" of the application. To prove that the transaction price is consistent with market price (Arm's length), the business must compare itself to independent businesses in similar industries.
- Reputable international data sources such as Orbis (Bureau van Dijk), Bloomberg, and Royalty Stat have extremely expensive annual access fees (up to tens of thousands of USD).
- A quality report requires financial data from competitors for at least three consecutive years.
FAR Analysis (Functions – Assets – Risks)
Consultants have to spend dozens of hours interviewing departments and conducting analyses:
- Functions: What stage in the value chain does the business perform?
- Assets: How do tangible and intangible assets (brand, technology) contribute?
- Risks: Who bears the market risk, inventory risk, and bad debt risk? The complexity of the FAR analysis is directly proportional to the cost of preparing the Related Party Transaction Profile.
Warning about the risks associated with excessively low costs for preparing related-party transaction documents.

Currently, many companies on the market are offering extremely low fees for preparing related-party transaction documents compared to the general market average. However, "you get what you pay for," and using these services carries unforeseen consequences for businesses:
Copy-Paste documents and falsified data
Low-cost providers often use a single template for all clients without performing actual FAR analysis. More dangerously, they may use unlicensed benchmarking data or fabricate figures. When tax authorities trace the data, this will be immediately rejected, resulting in the business losing all its service fees and facing penalties.
Lack of protection during inspections
Most providers offering low prices only go as far as delivering the files. When the tax inspection team comes to work and requests explanations of complex technical terms such as... Interquartile range good Weighted average, These entities often "disappear" or lack the expertise to protect the data they have compiled. Businesses are left to fend for themselves in this predicament.
Consequences: Turning "low cost" into "high consequences"“
A low-quality but substandard set of documents can become evidence against a business. Such documents demonstrate a lack of seriousness in complying with tax laws, giving the tax authorities grounds to expand the scope of their audit to include other fiscal years.
Price list for preparing Related Party Transaction Documents 2026
Below is a reference price list for preparing Related Party Transaction Documents by MAN – Master Accountant Network, to help businesses prepare their budget accordingly:
| Business group | Revenue scale | Characteristics of related party transactions | Reference fee |
| General business | Revenue < 50 billion VND | Only internal loan transactions or simple asset leases are permitted. | 25,000,000 – 45,000,000 |
| Small and medium enterprises | Revenue ranges from 50 to 200 billion VND. | Trading in finished goods and supporting services domestically. | 50,000,000 – 90,000,000 |
| FDI/Multinational enterprises | Revenue > 200 billion VND | Cross-border transactions, royalties, technical support, technology transfer. | 100,000,000 – 250,000,000 |
| Specialized corporation | High revenue threshold | The trading system is complex, requiring the creation of complete Local File, Master File, and CbCR. | Contact MAN – Master Accountant Network |
Note: The above price list is for reference only. The actual cost of preparing the Related Party Transaction Documentation will be quoted accurately after a specialist surveys the transaction status of each entity.
Why is doing it yourself more expensive than outsourcing?
Many chief accountants believe they can download templates online and fill them out themselves to save on the cost of preparing related-party transaction records. However, in reality, this is a costly mistake for the following reasons:
- Lack of professional databases: Without data from reputable financial institutions, comparisons that businesses find themselves on Google are often not accepted by tax authorities.
- Risk of methodological bias: Choosing the wrong valuation method will invalidate the entire application in the first round of evaluation.
- Opportunity cost: Accounting staff have to spend months researching, leading to errors in other important tax returns.
When the risk of being subject to retroactive tax collection is added up, it becomes clear that investing in the cost of preparing the Related Party Transaction Documentation is worthwhile. Related Party Transaction Documentation Service Professionalism is the most economically viable option.
The risks are immense if you don't invest adequately in your Related Party Transaction Profile.

Neglecting the documentation process or merely submitting low-quality documentation can lead businesses to a "money lost, trouble gained" situation. When transactions are not substantiated by sound economic arguments, the financial consequences for businesses are often tens, or even hundreds, of times greater than the initial cost of preparing the related-party transaction documentation. Below are the worst-case scenarios that managers need to pay particular attention to:
Penalties for administrative tax violations.
Although administrative penalties are just the initial step, they directly impact a company's legal compliance record.
- A fine of VND 8,000,000 to VND 15,000,000 will be imposed for submitting the related party transaction declaration (Appendix) more than 91 days after the deadline or for failing to submit the declaration at all.
- A fine of VND 5,000,000 to VND 8,000,000 will be imposed for the act of creating incomplete records or failing to update records periodically as prescribed by Decree 132.
- Penalty 20% is imposed on the amount of underdeclared tax or the amount of tax exempted, reduced, or refunded in excess of regulations: This is an extremely heavy penalty when inaccurate related-party transaction documents lead to omissions in corporate income tax settlement.
- Late payment penalty of 0.031 TP3T/day: Calculated on the amount of back taxes to be collected. This amount accumulates over time and can far exceed the cost of preparing the related-party transaction documentation that the business intends to save.
Tax Assessment Penalty
If the application is rejected, the tax authorities have the right to determine the profit margin. For example, they might determine a profit of 8% while the business is actually incurring losses. The business would then have to pay corporate income tax (20%) on this determined profit, plus late payment penalties and fines for incorrect declarations. The total amount could reach billions of VND.
Excluding interest expense
Decree 132 limits deductible interest expenses to 30% EBITDA. Poor quality documentation will fail to protect the reasonableness of loans, leading to the unfortunate disallowance of legitimate expenses.
To avoid risks, please refer to the following information. Related party transaction advisory services To receive support and assistance from MAN's pricing team.
The value and benefits of using professional services.
When deciding to allocate budget to this option hire someone to prepare related party transaction documents. At reputable consulting firms, the value that businesses receive far exceeds the initial cost of preparing the Related Party Transaction Documentation:
- Optimizing legal tax obligations: Determining the most advantageous “standard market value range” for the business.
- “A solid "shield" against inspectors: Experts directly explain and defend the data before the inspection team.
- Protecting brand reputation: Avoiding being named in the list of transfer pricing tax violators.
- Long-term strategic consulting: Forecasting and adjusting pricing policies for subsequent fiscal years.
Detailed implementation process at MAN – Master Accountant Network
To ensure the highest quality documentation and to withstand any questioning from the tax authorities, the service implementation process is carried out in 5 stages to guarantee the best possible quality documents:
- Step 1 – Health Check: This is the foundational step. Experts will review the entire transaction system, tax returns, and financial statements from previous years to identify risk areas. A tax health check helps businesses proactively correct errors before officially filing their tax return.
- Step 2 – Functional and Industry Analysis (FAR Analysis): MAN conducts in-depth research into the business model, clearly identifying what function each party in the transaction is performing (production, distribution, or service?), what assets they are using (tangible and intangible), and what risks they are bearing. This is the most important basis for selecting the appropriate valuation method.
- Step 3 – Benchmarking Study (International Data Retrieval): Utilize professional databases such as Orbis or Bloomberg to search for independent companies with the highest degree of similarity in industry, size, and market. This process helps determine an objective “benchmark market value range,” eliminating subjectivity in pricing.
- Step 4 – Drafting and Finalizing the Bilingual Report: The documentation is presented according to the standard structure of Decree 132, usually including both Vietnamese and English versions to serve both the tax authorities and the parent company abroad. Each argument is carefully refined to ensure logical consistency from the FAR analysis to the comparison results.
- Step 5 – Post-Audit Support and Explanation: The true value of our service lies in this step. We don't just deliver the documents and leave. When your business is audited, our experts will assist in explaining and defending your chosen methodologies and data, ensuring that the cost of preparing your Related Party Transaction Documentation truly provides complete peace of mind.
Conclude
The cost of preparing related-party transaction documents is essentially an insurance premium for a company's financial security. In 2026, the subjective choice of cheap services was the biggest loophole leading to unnecessary financial losses.
Instead of worrying about service costs, worry about the amount of tax you might be charged if you don't have a proper set of documents. Contact MAN – Master Accountant Network today for a detailed quote and free consultation!
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 the Cost of Preparing Related Party Transaction Documents
The cost of preparing a related-party transaction report depends primarily on four factors: the number and complexity of the related-party transactions, whether a benchmarking study is required, whether the company only needs a local file or also a master file and CbCR, and the quality of the data and the experience of the consulting firm. Firms that offer excessively low prices often only assist in filling out forms, without conducting comparative data analysis or developing sufficient arguments to defend the company during audits.
Typically, the comparative data analysis portion accounts for approximately 40% - 60% of the total cost of preparing the Related Party Transaction Documentation. This is the most expensive part because the consulting firm must utilize international databases, filter comparable companies, and establish appropriate market profit margins.
Businesses can handle transfer pricing themselves if the transaction is very simple and their accounting team has in-depth experience in transfer pricing. However, in most cases, doing it themselves often leads to: Lack of valid comparative data, selection of the wrong pricing method, and inability to explain the situation to the tax authorities during an audit. The immediate cost savings may be much smaller than the amount of back taxes and penalties later on.
Yes. The fee for hiring a consulting firm to prepare the related-party transaction documentation is considered an operating expense and is usually deductible when determining taxable income, provided there is a complete contract, invoice, and valid payment documentation.
The most appropriate time is at the beginning of the fiscal year or before tax settlement. If prepared early, the consulting firm can help the business adjust internal pricing policies, interest expense structure, and profit margins in advance, thereby reducing risk and optimizing the cost of preparing the Related Party Transaction Documentation.Why do different companies quote different prices for preparing related-party transaction documents?
What percentage of the total service fee is accounted for by the benchmarking study (comparative data)?
Is it possible to create my own related-party transaction profile to save costs?
Are the costs of preparing related-party transaction documents deductible expenses when calculating corporate income tax?
When should a business hire consultants to optimize costs?




