Amidst the rapid development of the digital economy and increasingly stringent international tax regulations, tax management for related-party transactions (NFIs) in Vietnam has entered a new era. This is especially true when... Law on Tax Administration No. 108/2025/QH15 Officially effective from July 1, 2026, along with the rigorous enforcement of the global minimum tax regulation, businesses not only face compliance pressure but also must optimize related-party transaction service fees to ensure sustainable financial performance and legal safety.
This article is comprehensively compiled to provide a roadmap for preparing standardized transfer pricing documentation, helping businesses avoid the risk of tax assessment and optimize transfer pricing service fees in their operations in 2026.
Understanding related-party transactions and the legal context from 2026 onwards.
To develop an effective tax management strategy, businesses first need to understand the core definitions and key changes in the current legal framework. Correctly identifying the nature of related-party relationships not only helps businesses comply with regulations but also forms the basis for optimizing operating costs. Below is a detailed analysis of the concept and the significant impacts of the international tax implementation roadmap.
What are related-party transactions? Definition according to the new regulations.
Related-party transactions are transactions that arise between parties that are related to each other in the production and business process. According to the regulations... Decree 20/2025/ND-CP, The related-party relationship is defined based on control, equity stake (minimum 25%), or direct/indirect operational influence. During operation, planning related-party transaction service fees in line with market realities is a mandatory requirement to demonstrate transparency to regulatory authorities.
The following types of transactions require special attention when accounting for them:
- Financial transactions: Internal borrowing, loan guarantees between entities within the group.
- Commodity trading: Buying and selling raw materials, semi-finished products, or finished products.
- Transactions involving intangible assets: Technology transfer, intellectual property rights, royalty payments.
- Internal service transactions: Corporate management fees, IT services, shared HR services.
Global minimum tax and double taxation risk
One of the biggest challenges in 2026 is the implementation of the Global Minimum Tax (GMT) mechanism. For multinational corporations with revenues exceeding €750 million, a minimum tax rate of 15% will be applied uniformly. If the related-party transaction service fees in Vietnam are not accurately determined, leading to under-adjusted profits, the business risks being subject to additional taxes in the parent company's country.
A lack of in-depth understanding of GMT (Gross Transaction Value) can lead to the risk of double taxation. Therefore, balancing related-party transaction service fees to achieve the desired outcome is crucial. Transfer pricing consultancy Consulting with experts on related-party transactions is a smart way to protect your finances. MAN – Master Accountant Network's transfer pricing experts will help businesses harmonize interests across countries, ensuring that the service fees for related-party transactions are completely secure and compliant with OECD international tax principles.
Challenges in comparative data analysis and the required expertise.
To explain matters to the tax authorities, businesses need an extremely in-depth set of benchmarking data. The quality of this data is usually directly proportional to the amount of related-party transaction service fees the business invests in:
Difficulty in finding corroborating data.
The process of identifying independent comparable entities requires a thorough understanding of financial indicators. Experts must sift through hundreds of financial reports across international databases such as Orbis or Bloomberg to find the most similar businesses. This is a time-consuming and costly process, explaining why the service fees for related-party transactions for these reports are typically not cheap if accuracy is to be guaranteed.
Reference: Transfer pricing services.
Differential adjustment technique
Each business has its own unique characteristics regarding working capital or asset size. Implementing technical adjustments requires a high level of mathematical and economic expertise. This is precisely what gives value to related-party transaction service fees, as they include the ability to protect data from rigorous audits by the Smart-Tax AI system.
Analysis of 5 Methods for Determining Transfer Pricing According to Decree 132
The choice of pricing method will determine whether the company's price is consistent with the Arm's Length Principle. Therefore, companies should seek advice. related party transaction advisory services To receive advice from our team on the most suitable methods for the industry and field in which your business operates.
- Independent Price Comparison (CUP) method: Direct price comparison. This is the optimal method but requires rigorous data collection, often resulting in high interbank transaction service fees due to the complexity of the search.
- Resale Price Method: Based on the resale discount. Suitable for commercial entities wishing to optimize related-party transaction service fees in filing.
- Cost Plus Method: Based on cost plus profit margin. Often applied to outsourcing companies when accounting for related-party transaction service fees.
- Net Profit Margin Comparison (NPMR): The most common method. The cost of running data for this method is a major component of the affiliate trading service fee.
- Profit Split Method: Designed for complex multinational transactions requiring high affiliate transaction service fees commensurate with the analysis value.
Detailed information on affiliate transaction service fees.
To help businesses gain a realistic perspective and easily plan their budgets, below is a price list for related-party transaction services, categorized by industry group and revenue size.
Related-party transaction service fees by industry group
The fees directly reflect the complexity of each sector. Below is a table of related-party transaction service fees by industry group:
| Industry Group | Key risk characteristics | Estimated related party transaction service fee (VND) |
| Processing and Manufacturing | Control the profit margin on costs. | 65,000,000 – 95,000,000 |
| Trade and Retail | Risk of exceeding advertising cost limits. | 75,000,000 – 130,000,000 |
| Real Estate and Construction | Evaluating internal borrowing costs is complex. | 115,000,000 – 195,000,000 |
| Logistics and Warehousing | International agency commission fees | 85,000,000 – 150,000,000 |
| Healthcare and Pharmaceuticals | Transfer pricing risk for monopolistic raw materials | 125,000,000 – 225,000,000 |
| IT and the Digital Economy | Royalties, expert fees | 135,000,000 – 285,000,000 |
| Renewable energy | Rent specialized equipment from overseas. | 145,000,000 – 255,000,000 |
The table above shows that related-party transaction service fees are not fixed but vary significantly depending on industry risk characteristics and transaction complexity. Sectors such as IT, pharmaceuticals, or renewable energy often have higher costs due to their involvement with intangible assets, intellectual property, or cross-border financial structures.
Related-party transaction service fees are based on business size and revenue.
To help businesses easily budget and choose the right service package, below is a price list for related-party transaction services in 2026, categorized by size and revenue. The fees are based on the complexity of documentation, transaction scope, compliance requirements under Decree 20/2025/ND-CP, and the impact of the Global Minimum Tax.
| Business group | Annual revenue (VND) | Local File creation fee | Package fee (Local + Master File) |
| SMEs | <50 billion | 35,000,000 – 55,000,000 | 60,000,000 – 85,000,000 |
| Medium-sized FDI enterprises | 50 - 250 billion | 65,000,000 – 110,000,000 | 120,000,000 – 180,000,000 |
| Large FDI enterprises | 250 – 1000 billion | 120,000,000 – 200,000,000 | 220,000,000 – 380,000,000 |
| multinational corporation | >1 trillion | According to actual transactions | Contact for agreement |
Note: The affiliate transaction service fee table is for reference only. Contact MAN – Master Accountant Network for detailed advice and specific pricing.
Why is investing in affiliate transaction fees a profitable economic proposition?
Investing in quality affiliate transaction service fees is not only about compliance but also yields benefits:
- Avoiding double taxation: Experts will coordinate a reasonable profit margin, helping to optimize the total service fees for related-party transactions and the taxes payable.
- Standardized benchmarking profile: Ensures data can withstand scrutiny from AI in the tax sector, thereby confirming the value of related-party transaction service fees by avoiding tax assessments.
- Save time on explanations: Shorten the time spent working with inspection teams by having thorough documentation from the outset.
The trap of lacking specialized expertise.
A worrying reality is that firms offering extremely low related-party transaction service fees often overlook complex GMT analyses. When tax authorities use in-depth financial comparisons to reject applications, those cheap related-party transaction service fees actually result in significant waste because they fail to protect the businesses.
Conclude
The year 2026 presents not only legal challenges but also opportunities for businesses to standardize their financial processes and enhance their reputation on the global economic map. Proper investment in related-party transaction service fees is a safeguard that helps businesses avoid risks related to global minimum tax policies on transfer pricing and errors in comparative analysis.
Contact MAN – Master Accountant Network For free support and advice!
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 Affiliate Transaction Fees
This regulation could easily lead to double taxation if profits are not accurately allocated between countries. The service provider's expertise helps adjust profit margins appropriately, ensuring compliance.
A reputable entity must possess access to copyrighted databases (like Orbis), have a team of experts knowledgeable in tax law, and be committed to supporting post-audit explanations. Extremely low fees for related-party transaction services often lack commitments to protecting actual data.
The new regulations require businesses to conduct additional analysis of the effective tax rate (ETR) in each country. The increased volume of analysis means that related-party transaction service fees are typically 20-30% higher than before, but this helps avoid the risk of additional taxation.
No. Each fiscal year requires updating the latest benchmarking data to accurately reflect market realities. Especially given the economic volatility of 2026, updating the data is mandatory to ensure that the related-party transaction service fees paid are legally valid.
Yes. Loss-making businesses are often targeted by transfer pricing audits. Properly documented transfer pricing helps demonstrate that losses arise from objective market factors rather than internal price adjustments, protecting the business from being taxed on revenue.Why do businesses need expert advice on global minimum tax rates?
How can you assess the credibility of an affiliate marketing service provider?
How do global minimum tariffs affect the cost of filing a GDLK application?
Is it possible to use comparative data from the previous year for 2026?
Do businesses that are operating at a loss need to declare it and prepare documentation to determine their costs?