In the context of the digital economy and tightening global tax regulations, transfer pricing regulations in Vietnam are entering a new, more stringent phase. This is especially true with the implementation of... Law on Tax Administration No. 108/2025/QH15 Issued on December 10, 2025 and officially effective from July 1, 2026, the Government has issued... Decree 255/2026/ND-CP Regulations on tax management for related-party transactions of affiliated enterprises replace Decree 132/2020/ND-CP (amended and supplemented by Decree 20/2025/ND-CP). Accordingly, self-declaration by enterprises is no longer simply filling out forms. This is why professional related-party transaction reporting services have become a vital financial shield for all affiliated enterprises.
Understanding the Related-Party Transaction Report correctly according to Decree 255/2026/ND-CP
Related-party transactions are transactions arising between parties that are related in the production and business process. From 2026 onwards, tax authorities will not only focus on multinational corporations and foreign direct investment (FDI) enterprises, but will also expand their scrutiny to include domestic private economic groups.
Which individuals are required to create a file?
According to Decree 255/2026/ND-CP (replacing Decree 132/2020/ND-CP and Decree 20/2025/ND-CP), businesses that have transactions with related parties (such as parent-subsidiary companies, companies within the same system, or individuals with family ties/large borrowing obligations) must fulfill the obligation to declare these transactions.
Regarding the threshold for determining related-party relationships through loans, businesses should note the following:
- The old rule remains in place: If one business lends to another business at least 25% of owner's equity, or the loan accounts for more than 50% of the total value of the borrower's medium and long-term debts, the two parties are determined to be related.
- New additions to Article 5 of Decree 255/2026/ND-CP: In addition to loan-lending relationships, the new Decree adds a related-party relationship arising from borrowing or lending at least 10% of the owner's contributed capital at the time the transaction occurs, applicable to individuals managing or controlling the business or individuals with family/relative relationships to those managing or controlling. This is a previously absent regulation, aimed at addressing the situation where businesses and managing individuals circumvent the obligation to declare related-party transactions by using the form of "borrowing money" (without interest).
- New exclusion: Decree 255/2026/ND-CP also adds a provision stating that a creditor or guarantor that is a state-owned organization with the function of buying, selling, or handling debt will not be considered an affiliated relationship if that organization does not directly or indirectly participate in managing, controlling, contributing capital, or investing in the debtor enterprise or the guaranteed enterprise.
These are points that many accountants often overlook, leading to delays in filing, which in turn results in serious consequences such as late payment penalties, back taxes, and even tax assessments.
Reference: Related party transaction advisory services.
List of required documents at 3 levels
A complete set of documentation for determining transfer pricing under the BEPS (base erosion control) standard includes:
- Local File: Focus on specific transactions of entities in Vietnam, as categorized in Appendix II issued with Decree 255/2026/ND-CP.
- Global Profile (Master File): This document provides an overview of the value chain and ownership structure of the entire corporation, according to the content categories in Appendix III issued with Decree 255/2026/ND-CP.
- Country-by-Country Profit Report (CbC Report): According to Decree 255/2026/ND-CP, the global consolidated revenue threshold for incurring the obligation to prepare a CbCR report has been adjusted to the equivalent of 750 million Euros or more (instead of the previous 18,000 billion VND), in order to align with exchange rate fluctuations and OECD guidance in BEPS Action 13. This revenue threshold is determined based on the revenue of the fiscal year immediately preceding the reporting year (instead of based on revenue during the tax period as before), and is converted using the central exchange rate or the average cross-exchange rate for December of the year published by the State Bank of Vietnam.
Businesses should conduct a review to see if they fall into one of the following categories: related party transactions To ensure accurate declarations are made, or when encountering difficulties or obstacles during the filing process and needing to avoid rejection, businesses should consult this information. related party transaction documentation service We source our services from reputable and experienced agencies to ensure your application is highly persuasive.
Deadline for submitting and archiving documents
Businesses must prepare transfer pricing documentation before submitting their annual Corporate Income Tax return. Although not required to be submitted directly (except for the appendices in Appendices I, II, and III issued with Decree 255/2026/ND-CP), businesses must retain and present this documentation within 15 working days upon request for inspection by the Tax authorities.
Specifically for the Country-by-Country Profit Report (CbCR), Decree 255/2026/ND-CP stipulates that the deadline for submission is no later than 12 months from the end of the fiscal year of the ultimate parent company of the reporting year. If a Vietnamese enterprise is designated by the ultimate parent company to submit the CbCR report on its behalf, the enterprise must also submit a Notification of the Entity to Submit the CbCR Report using Form No. 01/TB-BCLN. This notification only needs to be submitted once when the obligation arises; if there are any changes to the information compared to the most recent notification (including cases of termination of the obligation), the enterprise must update the information within 90 days from the date of the change.
Key new points in Decree 255/2026/ND-CP
According to Official Letter 4697/CT-CS of 2026 from the Tax Department, Decree 255/2026/ND-CP has several important new points that businesses need to be aware of to avoid errors in tax declarations:
- Raise the threshold for exemption from preparing Transfer Pricing Documentation: The revenue threshold for exemption from filing has been raised to below VND 500 billion (previously below VND 200 billion), and the criterion of "business with simple functions," which previously had to be met along with three other criteria, has been removed. This regulation expands the scope of low-risk businesses eligible for exemption from filing, simplifying the application conditions.
- Do not use the CbCR Report to set or adjust the price of related-party transactions. The decree adds a principle that tax authorities may only manage and use taxpayers' Country-by-Country Reports for risk management and information exchange in accordance with international commitments, and may not use them to adjust or fix transfer pricing.
- Add mechanisms to support voluntary compliance: The tax authorities will develop a program to support businesses with related-party transactions in voluntarily complying with risk management principles, and will also publish profit margins by industry, location, or taxpayer group to assist businesses in self-declaring and determining prices according to the arm's length principle.
- Database usage priority order: The decree for the first time clearly stipulates the order of priority when analyzing and comparing related-party transactions: (i) publicly available databases, (ii) commercial databases, (iii) tax authority databases; and also adds the National Database as a new data source.
- Transitional provisions regarding interest expense: Businesses subject to the transitional provisions regarding interest expense under Article 3 of Decree 20/2025/ND-CP will continue to apply the transitional provisions for the remaining period, ensuring policy continuity.
See also: New points in Decree 255/2026/ND-CP regarding related-party transactions.
Serious risks arise if businesses ignore the Related-Party Transaction Report.
Many businesses still hold the subjective view that simply submitting the supplementary declaration is sufficient. However, the actual risks are far more serious:
Taxes and profits are assessed.
If the documentation is incomplete or the pricing method is inappropriate, the tax authorities have the right to determine the price or profit margin based on industry data. In practice, this determined amount is often much higher than the actual figures recorded by the business, potentially resulting in tax arrears of tens of billions of dong. Note that, according to the new provisions in Decree 255/2026/ND-CP, the CbCR report alone will... Are not It is used as a basis for determining the price of related-party transactions.
Interest expense trap exceeds 30% EBITDA
According to Article 16 of Decree 132/2020/ND-CP (now inherited in Decree 255/2026/ND-CP), the total interest expense deductible when determining corporate income tax shall not exceed the total net profit from business operations plus interest expense and depreciation expense. Without financial structure advice from a related-party transaction reporting service, businesses are very likely to have a series of legitimate expenses disallowed.
Administrative penalties and late payment fees.
The penalties for failing to file or filing incorrectly are currently very heavy. In addition, late payment fees calculated at 0.031 TP3T/day on the amount of back taxes collected can create a significant financial burden, potentially rendering businesses unable to pay.
Listed as a High Risk Taxant
When assessed as having transfer pricing risks, businesses will be subject to annual audits instead of every 3-5 years. This places immense pressure on the accounting department and daily operations.
Serious damage to reputation and image.
Outsourcing to a competent related-party transaction advisory firm is not an expense, but a smart investment to protect assets.
Misconceptions about bank loan relationships
This is a newly emerging and very common risk. Many businesses mistakenly believe that borrowing from banks is a transaction with an independent party. However, according to regulations, if a loan accounts for more than 50% of the total value of the company's medium and long-term debts, that bank will be considered an affiliated party. Furthermore, since Decree 255/2026/ND-CP, the lending relationship between a business and its managing or controlling individuals can also be classified as an affiliated relationship if it reaches 10% of the owner's equity contribution. Failure to update these regulations leads to omissions in declarations, resulting in interest expenses being outright disallowed during audits, causing significant financial losses.
See details: Is taking out a bank loan considered a related-party transaction?
Benefits of using a professional Related Party Transaction Reporting service.
Outsourcing to a competent and experienced related-party transaction tax consulting firm is not an expense, but a smart investment to protect your assets.
Optimizing the amount of tax payable legally.
Units specializing in related-party transaction reporting services, such as MAN – Master Accountant Network, have access to global comparison data systems like Orbis (Bureau van Dijk) or Thomson Reuters. From there, they can find similar businesses with suitable profit margins to protect the revenue and profits of the business's transactions.
Absolute safety from tax inspectors.
The documentation is prepared by experienced professionals who have gone through numerous explanations before tax inspectors, thus possessing a thorough understanding of the process and the focus of the inspection. MAN not only prepares reports but also builds a solid system of reasoning, providing logical explanations behind the figures, helping businesses confidently face regulatory authorities.
Unleash internal resources
Instead of the chief accountant spending months researching complex and error-prone international tax regulations and policies regarding related-party transactions, a comprehensive Related-Party Transaction Reporting service handles everything. This allows the company's team to focus on internal business activities.
The process for implementing the Related Party Transaction Reporting service at MAN – Master Accountant Network.
MAN applies a rigorous 5-step process to ensure client documents meet regulatory standards:
- Step 1 – Review and identification: Examine the entire company structure to identify related parties (including lending and borrowing relationships as per new regulations) and types of transactions (buying and selling goods, providing services, borrowing capital, copyrights, etc.).
- Step 2 – Perform FAR Analysis (Functions, Assets, and Risks): Conduct an in-depth analysis of the functions, assets, and risks that each party is responsible for in the value chain. This is the most important step in the related-party transaction documentation.
- Step 3 – Selecting appropriate pricing methods and comparative data (Benchmarking): Select the most appropriate pricing method, use the correct database priority order as stipulated in Article 17 of Decree 255/2026/ND-CP, and conduct comparative data analysis using specialized software.
- Step 4 – Complete the application: Prepare a complete set of national dossiers, corporate dossiers, and accompanying appendices according to the forms in Appendices I, II, and III issued with Decree 255/2026/ND-CP.
- Step 5 – After-sales service: We support businesses throughout the process of explaining their financial data when tax inspectors visit their premises or during emergency inspections.
Price list for services to prepare detailed Related Party Transaction Reports 2026
Below is a reference price list to help businesses easily estimate their budget. The exact fee will depend on the number of transactions and the complexity of the industry:
| Service categories | Transaction size | Estimated fee (VNĐ) | Execution time |
| Declaration package | Under 10 billion VND | 15,000,000 – 25,000,000 | 5-7 business days |
| Basic Local File Package | 10 – 50 billion VND | 40,000,000 – 65,000,000 | 7-10 business days |
| Advanced Local File Package | 50 – 150 billion VND | 70,000,000 – 110,000,000 | 10-15 business days |
| Local File + Master File | Over 150 billion VND | Contact for agreement | 15-30 business days |
| Independent risk review | Unlimited | 20,000,000 – 35,000,000 | 5 working days |
Note: The prices listed are for reference only and reflect the general market rates. Contact MAN – Master Accountant Network for free consultation and a detailed quote!
Why should businesses choose MAN's Related Party Transaction Reporting service?
With over 30 years of experience in tax and transfer pricing consulting, we are proud to offer high-quality, professional Transfer Pricing Reports services:
- Strong expertise: Our team consists of CPA-certified experts and tax agents with experience working with the Tax Authority, always keeping up-to-date with new regulations such as Decree 255/2026/ND-CP.
- Reliable data: Utilizing internationally licensed data sources in accordance with the priority order stipulated in Decree 255/2026/ND-CP, ensuring legal validity when compared with data from Vietnamese tax authorities.
- Absolute confidentiality: We are committed to protecting our clients' business information and pricing strategies through legally binding documents or contractual terms.
- Practicality: We don't just offer theory; we protect your business's profile until it's approved.
Conclude
A well-prepared set of documents not only helps businesses comply with the regulations in Decree 255/2026/ND-CP, but also serves as solid evidence for transparent explanations, protecting profits and reputation in any inspection.
If your business is:
- Transactions with affiliated parties have occurred but have not been fully reviewed according to the new regulations;
- Concerns about the risks of interest expenses and tax assessments;
- Alternatively, you may need to optimize your application according to Decree 255/2026/ND-CP.
Don't wait until you're audited to start addressing issues. Let the expert team at MAN – Master Accountant Network – support your business in controlling risks and optimizing legal tax practices for peace of mind.
Contact MAN – Master Accountant Network For detailed advice 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
- E-mail: man@man.net.vn
- Google Business Profile: View MAN – Master Accountant Network's Google Business Profile
- LinkedIn Founder: View expert Le Hoang Tuyen's LinkedIn profile.
Responsible for production and professional content review by: Mr. Le Hoang Tuyen – Founder & CEO of MAN – Master Accountant Network. He is a CPA Vietnam auditor with over 30 years of in-depth experience in accounting, auditing, taxation, and corporate legal consulting.
Frequently Asked Questions about the Affiliate Transaction Reporting Service
When should businesses use a Transfer of Interest Reporting service?
Businesses are required to prepare documentation when transactions with related parties occur, according to Decree 255/2026/ND-CP, except in cases eligible for exemption (revenue under VND 500 billion and meeting the exemption criteria as stipulated in the new regulations). Using a service to prepare the Related Party Transaction Report is necessary when the transaction structure is complex, involves large borrowings or loans, or when it is necessary to ensure the documentation meets standards to avoid the risk of tax assessment.
How does a related-party transaction reporting service help reduce the risk of tax arrears?
This service helps build a business profile based on market pricing principles, performing FAR analysis and benchmarking using independent comparative data according to the priority order of the database as stipulated in Decree 255/2026/ND-CP. As a result, businesses have a basis to demonstrate reasonable pricing, reducing the risk of profit margins being assessed, tax arrears, and penalties during tax audits.
Do bank loans need to be declared in the Related-Party Transaction Report?
According to regulations, a bank may be considered an affiliated party if the loan accounts for a significant proportion of its capital structure (over 50% of the total value of medium and long-term debt). Therefore, businesses need to carefully review the loan-to-equity ratio requirements to determine their declaration obligations and avoid omissions that could lead to the risk of disallowing interest expense.
What is the deadline for preparing documentation for related-party transactions?
Businesses must complete their tax return before the corporate income tax filing deadline. While not required to submit immediately, they must be ready to provide the documents within 15 days of request from the tax authorities. The CbCR report has a separate deadline of 12 months from the end of the fiscal year of the parent company. Early preparation helps avoid pressure and ensures data accuracy.
Why should you hire a service to prepare your Related Party Transaction Report instead of doing it yourself?
Preparing tax returns independently requires in-depth knowledge of taxation and international comparative data, especially given the recent changes to regulations in Decree 255/2026/ND-CP. Professional services help businesses access standardized data, build strong arguments, and ensure compliance with new regulations, thereby minimizing risks and optimizing financial performance.
What are the risks involved when an individual borrows money from a company or a business borrows money from an individual for operational purposes without interest?
According to Decree 255/2026/ND-CP, lending transactions between individuals managing or controlling a business (or individuals related to the managers) and the business, if they reach at least 10% of the owner's equity at the time of the transaction, will be classified as related-party transactions. If interest is not calculated at market rates, the tax authorities may determine interest income based on the bank interest rate at the time of the transaction.