MAN's expert team of certified tax service professionals (CTA) and certified public accountants (CPA) in Tan Phu District provides optimal protection against the tightening of transfer pricing audits under the latest Decree 255/2026/ND-CP. Did you know that even a small discrepancy in classifying related parties or valuing loan transactions can lead to administrative penalties for tax violations and unfavorable transaction pricing of billions of VND?
Particularly since Decree 255/2026/ND-CP officially came into effect on July 1, 2026, completely replacing Decree 132/2020/ND-CP, all businesses with related-party transactions in the area are required to immediately switch from the usual self-declaration method to a systematic document control system, ensuring absolute transparency before the law.
Why is related party transaction advisory services in Tan Phu District urgently needed today?
Tan Phu District, with its numerous small industrial clusters, representative offices, FDI enterprises, and family-owned companies with parent-subsidiary models, is witnessing a strong wave of business linkages. In the context of tax authorities applying modern information technology and big data to cross-link transaction information nationwide, unverified self-declarations create a huge risk loophole.
Having the documentation reviewed and prepared by an independent unit is the best way to help businesses confidently explain their actions. A consultant familiar with the Tan Phu district area will help identify unusual transactions within the internal system early on, allowing for timely adjustments before an inspection decision is made.
Legal basis according to current regulations on related-party transactions.
Tax management for businesses with related-party transactions in Vietnam is strictly operated based on the following core legal documents:
- Tax Administration Law No. 38/2019/QH14 (and related supplementary and amendment documents): Regulations on the arm's length principle for transactions between related parties aim to eliminate factors that reduce tax liability due to related-party relationships.
- Decree 255/2026/ND-CPIssued on June 30, 2026 and effective from July 1, 2026 (applicable from the corporate income tax period of 2026). This Decree completely replaces Decree 132/2020/ND-CP and Decree 20/2025/ND-CP, bringing about many pivotal changes that businesses are required to update.
- To proactively comply with the law and avoid missing key updates from regulatory authorities, businesses need to carefully study the following: New points in Decree 255/2026/ND-CP This is to avoid misapplying the law when optimizing financial costs.
- In addition, proper application loan interest calculation formula Setting a maximum ceiling on EBITDA (after deducting interest on deposits and loans incurred during the period) is key to preventing businesses from unfairly having their financial expenses disallowed. This non-deductible interest expense will be carried forward to the next tax period when determining the total deductible interest expense over a period not exceeding five consecutive years.
Key new points of Decree 255/2026/ND-CP that businesses need to be aware of.
To avoid serious legal errors, businesses in Tan Phu District need to be familiar with the highly practical changes in the new Decree:
- Adding borrowing and lending transactions to related-party relationships: According to Point l, Clause 2, Article 5 of Decree 255/2026/ND-CP, a related-party relationship is defined if an enterprise engages in borrowing and lending transactions involving at least 10% of owner's contributed capital at the time the transaction occurs during the tax period with individuals managing or controlling the enterprise, or individuals with close relationships (spouse, parents, children, siblings, grandparents, grandchildren, etc.). This regulation prevents enterprises from transforming the nature of financial borrowing transactions into loan agreements to evade declaration obligations.
- Raising the revenue threshold for exemption from preparing Transfer Pricing Documentation: The Decree greatly facilitates small and medium-sized enterprises by raising the revenue threshold for exemption from preparing Transfer Pricing Documentation from under VND 200 billion to under VND 500 billion in the tax period. This applies to taxpayers conducting business that does not generate revenue or expenses from the exploitation or use of intangible assets and meets the minimum profit margin before deducting interest expenses and corporate income tax on net revenue (the corresponding minimum margins are: distribution 5%, manufacturing 10%, processing 15%).
- Changes to the revenue threshold for submitting Country-by-Country Profit Reporting: The threshold has been changed from the previous fixed figure of 18 trillion VND to a global consolidated revenue equivalent of 750 million Euros or more in the fiscal year immediately preceding the reporting year, ensuring full compliance with OECD international standards.
- Additional exception regarding debt linkages: Point d.3, Clause 2, Article 5 of the Decree adds an exception excluding the relationship between the creditor or guarantor of the loan in cases where the creditor or guarantor is a state-owned organization with charter capital that has the function of buying, selling, and processing debt (such as DATC, VAMC) and these organizations do not directly or indirectly participate in the management, control, or capital contribution of the borrowing enterprise.
Target audience for related party transaction advisory services in Tan Phu District.
Any business that has related-party relationships according to the criteria of control, capital contribution, direct/indirect management, or engages in lending or borrowing transactions as defined in the new Decree 255/2026/ND-CP is subject to the law. Below is a summary table of entities that should prioritize receiving related-party transaction advisory services in Tan Phu District:
| Type of business | Characteristics of needs | Priority level |
| FDI enterprises | Transactions involving the purchase and sale of raw materials, technology transfer, payment of management fees, or financial transactions with the foreign parent company arise. | Obligatory |
| Domestic parent-subsidiary companies | Internal lending, borrowing or lending of assets, payment guarantees, and transfer of assets between members of the group. | Very high |
| Businesses with a shared CEO | Transactions arising between two independent legal entities that share a common legal representative, board member, or a closely related individual who controls them. | High |
| Businesses that receive tax incentives | Transactions between member units with different corporate income tax rates are intended for profit shifting. | Obligatory |
Strategic benefits of implementing related party transaction advisory services in Tan Phu District.
Collaborating with specialized external units like MAN – Master Accountant Network ensures absolute security and transparency. We act as an objective third party, helping businesses optimize their records and eliminate the subjective thinking of inexperienced internal accounting teams regarding transfer pricing and the complex technical regulations of Decree 255/2026/ND-CP.
Early detection of critical risks
MAN's auditors and tax experts will conduct a thorough review of all internal loan, purchase, and service contracts. We analyze discrepancies between internal pricing and independent market prices, identifying potential profit margin risks so that businesses can make timely adjustments before tax authorities conduct an audit.
Optimizing costs and operational efficiency.
Many businesses in Tan Phu district inadvertently incur high tax rates due to interest expense deductions exceeding the prescribed limit. Professional consulting services help businesses restructure internal loans, rearrange trade payment methods, and optimize the tax burden arising from related-party transactions each year, from 10% to 20%.
Procedures for implementing related-party transaction advisory services in Tan Phu District
At MAN – Master Accountant Network, we have developed a standardized service roadmap consisting of 5 rigorous steps to deliver the highest efficiency for businesses:
Step 1: Survey the relationship and define the scope of the transaction.
We conduct a survey of ownership structure, family relationships, and financial agreements to accurately determine whether the business falls within the scope of related-party transactions as stipulated in Decree 255/2026/ND-CP. From there, we identify the transactions involved to plan for proper tax declaration.
Step 2: Analyze the database for independent comparison.
Using a global trade database system and prioritizing publicly available data sources according to the new regulations of the General Department of Taxation, MAN searches for similar independent businesses operating in Vietnam to scientifically compare profit margins.
Step 3: Prepare documentation for determining transfer pricing.
We perform calculations and select the most optimal pricing method (independent transaction price comparison method, profit margin method, etc.) to establish a set of options. related-party transaction pricing documentation Complete, thorough, and in accordance with the regulations of the General Department of Taxation.
Step 4: Complete the Related Party Transaction Information Forms
We assist businesses in completing all required forms attached to the annual Corporate Income Tax Return. This includes the use of... related party transaction documentation service MAN ensures that the figures on the declaration form are 100% consistent with the group's national and global records.
Step 5: Assist in explaining and defending data during tax audits.
Our team of experienced professionals will represent or assist businesses in providing detailed explanations to the Tan Phu District Tax Authority regarding the methods used to select comparable businesses, ensuring smooth approval of the application.
Standard information declaration versus in-depth valuation documentation.
Businesses often mistakenly believe that simply submitting the Related Party Transaction Information Declaration (Form attached to tax return) is sufficient. However, the declaration is only the first step; the accompanying supporting documents are crucial and will determine the outcome during an audit.
| Criteria | Standard information declaration | Prepare a valuation report. |
| Purpose | Provide a preliminary declaration of related parties and the value of transactions arising during the tax period. | Demonstrate the validity of the pricing method based on the principle of independent transactions under the same conditions. |
| Storage location | Submit online along with the annual Corporate Income Tax Return. | Keep on file at the business premises and present immediately upon request from a tax audit (within 15 working days). |
| Complexity | For low-level accountants, it's usually best to fill in the figures directly from the accounting books. | Very demanding, requiring in-depth comparative database analysis and a deep understanding of transfer pricing tax law. |
| Legal | This is mandatory for all businesses that have related-party transactions. | It is mandatory for businesses that are not exempt to file documents as stipulated in Decree 255. |
Risks if businesses do not use related party transaction advisory services in Tan Phu District.
Self-preparing documents without accurate verification data or ignoring the declaration requirements under the new law will put businesses in a seriously disadvantageous position.
The tax authorities imposed a high selling price and demanded substantial back taxes.
If the documentation fails to prove the objectivity of the transaction, the tax authorities have the right to reject the internal pricing and determine the profit margin themselves based on the tax department's database. The amount of corporate income tax arrears, along with a late payment penalty of 0.03% per day, could amount to a huge sum, threatening the survival of the business.
Risk of eliminating all interest expense exceeding the ceiling.
Without a thorough understanding of the law, corporate accountants will be unable to properly handle interest expense exceeding the ceiling limit under Circular 30%. The lack of specialized consulting services leads to the loss of the right to carry forward interest expenses to subsequent tax periods, causing businesses to suffer unnecessary financial losses.
Tips for choosing a reputable related party transaction advisory service provider in Tan Phu District.
Amidst a landscape of many low-cost accounting service providers lacking in-depth expertise in related-party transactions, businesses in Tan Phu should carefully consider the following criteria:
- Certified and reputable team: Prioritize firms with experts holding CPA certifications and certified transfer pricing agents (CTAs) with many years of practical experience in the field.
- Possessing a database for comparing copyrights: Transfer pricing filing requires authentic comparative data from reputable sources approved by the General Department of Taxation. A reputable entity will be able to demonstrate the cleanliness of the data they use.
- Experience working directly with the local tax office: A thorough understanding of the working procedures of the Tan Phu District Tax Office helps optimize the time spent on explaining documents quickly and efficiently.
Reference price list for related party transaction advisory services in Tan Phu District.
MAN's service fees are designed to be flexible, based on business size, the number of related parties, and the complexity of the transactions involved.
| Business size | Transaction characteristics | Estimated fee (VNĐ) |
| Small and medium enterprises | The transactions mainly involved borrowing or simple buying and selling. | 15,000,000 – 30,000,000 |
| Large-scale enterprises | Complex transaction (including franchise fees, management fees) | 30,000,000 – 50,000,000 |
| Multinational corporations, FDI enterprises | Diverse, cross-border transaction chain | Contact for agreement |
Note: The above price list is for reference only. The exact cost will be quoted after a MAN expert conducts a free business structure survey.
MAN – Master Accountant Network: A trusted partner in Tan Phu District
If your business is struggling with data standardization or worried about an upcoming tax audit under the stricter regulations of the new Decree, MAN – Master Accountant Network is your most reliable partner.
With a network of financial experts and auditors specializing in transfer pricing, we not only provide solutions for resolving related-party transaction issues but also support businesses in building a safe operating structure and optimizing tax costs legally.
Let MAN's related party transaction advisory service in Tan Phu District become a solid legal foundation for the sustainable development of your business. Contact Contact us today to receive advice from leading experts!
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.