In the context of Vietnam's General Department of Taxation intensifying audits based on big data and OECD standards, businesses with related-party transactions are facing increasingly high risks of tax assessment, back taxes, and penalties. Therefore, transfer pricing services have become a crucial financial shield, helping businesses comply with regulations, build a solid record, and proactively prevent transfer pricing risks. This article will provide a comprehensive overview of the tax audit landscape in 2026, core regulations, and standard documentation procedures that businesses cannot ignore.
Current status of tax management and transfer pricing risks in 2026
Entering 2026, the Vietnamese tax authorities officially launched a centralized data analysis system utilizing artificial intelligence (AI). This system allows for data exchange with over 100 countries and territories, helping to identify unusual transactions within corporations in just seconds.
The wave of tax audits focuses on related-party transactions.
Previously, transfer pricing audits focused primarily on large foreign-invested enterprises (FDI), but now the scope has expanded to include small and medium-sized enterprises with domestic affiliations. Audits conducted in 2024-2025 revealed that over 701 businesses were found to have errors in preparing documentation for determining transfer pricing, resulting in substantial tax arrears.
Potential risks of not using professional transfer pricing services.
Many businesses still maintain a do-it-yourself mindset to save costs, but in reality, a lack of legal knowledge can lead to disastrous consequences for the business itself.
- Tax assessment: This is the most frightening risk. When your application is rejected due to failure to prove the independence of the transaction price, the tax authorities have the right to use industry databases to determine the profit margin. The result is often a tax liability many times higher than the actual business value.
- Tax arrears and late payment penalties: According to regulations, the administrative penalty for tax violations is 201 TP3T on the amount of tax owed. Adding late payment interest of 0.031 TP3T/day calculated on the overdue tax amount, after a few years of audit, this amount could exceed the registered capital of a medium-sized enterprise.
- Type of interest expense (EBITDA): Decree 132/2020/ND-CP And the latest guidance documents from 2026 stipulate very strict limits on interest expense deductions (30% EBITDA). Without advice from transfer pricing services, businesses can easily miscalculate, leading to tens of billions of dong in interest expenses being disallowed as deductible expenses when calculating corporate income tax.
- Damage to brand reputation: Being named on a list of companies owing taxes or violating transfer pricing regulations will directly affect credit ratings, making it difficult to obtain bank loans or participate in international bidding projects.
Understanding the regulations for determining transfer pricing correctly.
To build a sustainable compliance strategy, businesses need to understand the legal pillars in operation and how to apply transfer pricing in practice.
Subjects and related parties
The relationship between a parent company and a subsidiary is not limited to the parent company holding equity in the subsidiary. According to current regulations, such relationships are also defined through:
- Hold directly or indirectly at least 25% of the owner's equity.
- One business manages and controls the personnel and financial decisions of another business.
- Both businesses are under the control of a third party.
- Loan and borrowing transactions account for at least 25% of equity capital and more than 50% of the total value of medium and long-term debt.
See details: Methods for identifying related-party transactions.
Arm's Length Principle
This is a core principle for all related-party transactions. It requires that transactions between related parties be conducted under the same conditions and at the same prices as transactions between independent parties under comparable conditions. Related-party transaction pricing services help businesses find a standard range of independent transaction values for scientific and accurate comparison.
Methods for determining prices according to Decree 132
Depending on the nature of the profession or field, choose the appropriate method. Below are 5 methods corresponding to the professions and fields as follows:
- The Comparable Prices of Independent Transactions (CUP) method: Direct comparison of product prices.
- Resale Price Method: Suitable for trading and distribution businesses.
- Cost Plus method: Suitable for manufacturing and processing businesses.
- The Net Profit Margin (NPRI) comparison method: The most common method in Vietnam today.
- Profit Split Method: Applicable to specific transactions involving complex intellectual property.
The process for implementing MAN – Master Accountant Network's transfer pricing service.
A convincing anti-transfer pricing dossier that will impress the inspection team needs to be systematically prepared with the support of a transfer pricing service through 6 steps:
Step 1: Perform FAR Analysis (Functions – Assets – Risks)
This forms the basis of the entire dossier. MAN focuses on in-depth analysis:
- Function: What functions does the business perform (Production, R&D, Marketing, Distribution)?
- Assets: What assets does the business use (machinery, technology, brand)?
- Risk: Who bears the burden of market risk, bad debt risk, and exchange rate risk?
Core principle: The party that bears more risks and performs more critical functions will have a higher profit margin.
Step 2: Choose a valuation method
Based on FAR analysis, experts from the related-party transaction pricing service will select the method with the least error margin and best suited to the company's existing data.
Step 3: Find independent benchmarks for comparison.
This is the most difficult step for businesses to perform on their own. When using MAN's transfer pricing service, we use internationally licensed databases such as Orbis, Moody's, and Bloomberg to find at least 3-5 independent businesses with similar functions to use as benchmarks.
Step 4: Adjust for significant differences
Any comparison is flawed without adjusting for factors such as capital size, payment terms, and market position. Complex mathematical techniques will be applied by the transfer pricing service provider to bring the entities to a level playing field for comparison.
Step 5: Prepare the 3-level application file.
To meet the global BEPS (Business Performance Standards), businesses need to prepare:
- National Profile of Related-Party Transactions (Local File): Details of transactions in Vietnam.
- Master File: Information about the value chain and operations of the entire parent company.
- Country-Based Profitability Report (CbC Report): For large corporations with consolidated global revenue exceeding VND 18 trillion.
Step 6: Fill out the appendix forms.
Complete Form 01 (Information on Related Parties), Forms 02, 03, and 04 to submit with the corporate income tax return. Errors in these forms are extremely serious and serve as grounds for inspection teams to audit the business. Therefore, support from a transfer pricing service is crucial.
Why do businesses need professional transfer pricing services?
Self-preparation of transfer pricing documentation often comes with significant risks regarding legal compliance and data accuracy. Here are three reasons why businesses prefer to choose a transfer pricing service:
- Access to international databases: Databases like Orbis have annual maintenance costs of tens of thousands of USD. Reputable and professional companies providing transfer pricing services are willing to invest these resources to serve their clients.
- Practical experience: The consultants have worked extensively with inspection teams; they understand the working methods of tax officials, know which weaknesses are often targeted, and how to provide the most reasonable explanations.
- Optimizing financial structure: Beyond compliance, transfer pricing services help businesses review their governance systems, thereby optimizing cash flow and tax costs within permissible limits.
Price list for transfer pricing services in 2026
MAN understands that each business has different sizes and transaction characteristics. Below is a reference fee table for transfer pricing services, based on the general market rates for consulting services in 2026:
| Service categories | Implementation content | Estimated fee (VNĐ) |
| Risk Review and Declaration Package | Review existing related-party transactions and prepare Form 01-04. | 15,000,000 – 30,000,000 |
| Create a Local File | Perform FAR analysis, benchmarking, and generate complete Local File reports. | 65,000,000 – 130,000,000 |
| Create a Corporate Master File | Transfer and localize company records from the parent company to the business in Vietnam. | 75,000,000 – 150,000,000 |
| Prepare a Country-by-Country Report (CbCR). | For large corporations with consolidated global revenue exceeding VND 18 trillion. | Contact for agreement |
| All-inclusive package | All records and direct support for explanations during inspections. | 200,000,000 – 350,000,000 |
| Independent benchmarking data | Provide a list of comparable businesses and their financial metrics. | 30,000,000 – 50,000,000 |
Note: The above price list for transfer pricing services is for reference only. The actual fee will be quoted in detail after a site survey.
Commitment from MAN – Master Accountant Network
When choosing MAN – Master Accountant Network's transfer pricing service, your company will receive:
- Absolute authenticity: All benchmarking data is extracted from data sources recognized by the Ministry of Finance.
- Information security: 100% is committed to protecting business data through written agreements or terms in the transfer pricing service contract.
- Long-term partnership: Our team of experts from the transfer pricing service will work closely with businesses throughout the entire process of explaining transactions to the tax authorities.
- Tax optimization: Providing recommendations to help businesses adjust their internal pricing policies accordingly.
Reference: Related party transaction advisory services
Conclude
With tax authorities increasingly tightening regulations and applying international standards from the OECD, compliance with related-party transaction regulations is no longer an option but a mandatory requirement for sustainable business development. Transfer pricing services are a solution that helps businesses not only prevent the risk of tax arrears and assessments but also optimize their financial structure legally and effectively.
If your business has related-party transactions or is unsure about its current compliance level, now is the right time for a comprehensive review. Contact MAN's related-party transaction experts for a risk assessment and to build a compliance profile.
For any questions, support, or advice, please contact MAN – Master Accountant Network via:
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 production by: Mr. Le Hoang Tuyen – Founder & CEO MAN – Master Accountant Network, Vietnamese CPA Auditor with over 30 years of experience in Accounting, Auditing and Financial Consulting.
Frequently Asked Questions about Transfer Pricing Services
Businesses must complete their documentation before submitting the Corporate Income Tax Return (usually 90 days after the end of the fiscal year). However, documentation should only be submitted upon written request from the tax authorities. Prepare the necessary documents within the 15-30 day period as stipulated.
Related parties are identified through equity ownership (above 25%), direct or indirect management rights, or debt relationships exceeding 50% of total medium and long-term debt. The related-party transaction valuation service reviews ownership structure and cash flow to accurately identify related parties, avoiding omissions that could lead to legal risks.
The most serious risk is having the self-declared data rejected by the tax authorities, leading to an assessment of corporate income tax. In that case, the business would have to pay tax based on the assessed profit margin, along with a penalty of 20% and late payment interest of 0.03%/day. A professional transfer pricing service will eliminate this risk by providing accurate comparative data.
The portion of interest expense exceeding the 30% EBITDA ceiling will be excluded from deductible expenses when calculating corporate income tax but can be carried forward to the next tax period (for no more than 5 years). Transfer pricing services assist businesses in accurately calculating this threshold and optimizing their financial plans to minimize tax losses.
Yes, if related parties have different tax rates or are enjoying tax incentives. Documentation helps to transparently reflect the value of domestic transactions, preventing allegations of profit shifting to entities with lower tax rates. This is a crucial aspect that related-party transaction pricing services frequently advise diversified corporations on.
MAN utilizes reputable international databases such as Orbis (Bureau van Dijk) or Moody's to search for independent entities that are functionally and risk-wise comparable. Using authoritative, copyrighted sources ensures the highest level of legal validity when businesses explain their transaction pricing to tax inspectors.What is the deadline for submitting transfer pricing documentation?
How can you identify an affiliated business?
What is the biggest risk when a related-party transaction profile does not meet the standards?
How are interest expenses exceeding the 30% EBITDA threshold handled?
Do domestic businesses need to prepare documentation to determine transfer pricing?
Where does the benchmarking data for transfer pricing services come from?