The 2026 pricing for transfer pricing services is not merely a compliance cost, but a strategic investment that helps businesses mitigate the risk of tax audits and optimize their financial obligations. As tax authorities intensify their oversight using AI and big data, selecting the right specialized consulting firm that specializes in Decree 132/2020/ND-CP and relevant guidelines and policies are vital to protecting businesses from the risk of having to pay back billions of dong.
Related-Party Transactions and Compliance Pressure
What are related-party transactions? Simply put, these are transactions that occur between parties with a related-party relationship (parent-subsidiary, within the same corporate group, or where there is significant control over capital or management). According to Decree 132/2020/NĐ-CP, these transactions must be conducted in accordance with the arm’s-length principle.
Why is 2026 an important milestone for businesses?
- Digitalization of Tax Data: The electronic invoice system and the Automatic Exchange of Tax Information (AEOI) have been fully implemented, enabling authorities to easily detect anomalies in profit margins with just a few big data queries.
Widespread Inspection Campaign: Industries with high rates of related-party transactions—such as textiles and apparel, electronics, and real estate—are a key focus of the inspection teams. - Tax Assessment Risk: If a business cannot provide documentation proving the reasonableness of its transfer pricing, the tax authority has the right to assess the tax based on the comparable data it possesses, which could result in back taxes and late payment penalties amounting to billions of dong.
Obtaining quotes for affiliate transaction services early in the fiscal year is an essential preparatory step that allows businesses to proactively manage their budgets and documentation, thereby avoiding a last-minute scramble.
Detailed 2026 Price List for Affiliate Transaction Services
Service fees are determined based on the complexity of the transaction, the number of related parties, and requirements for international comparative data. Below is the most recently updated reference pricing framework for related-party transaction services.
Price List for Affiliate Transaction Services by Business Size.
To help businesses easily understand the costs and choose the appropriate service package, below is a price list for affiliated transaction services, categorized by revenue size and scope of work. This table reflects common market rates and strictly adheres to the compliance requirements set forth in Decree 132/2020/NĐ-CP, ranging from basic reporting to the preparation of a complete set of documentation, including the Local File and Master File.
| Business group | Annual Revenue | Service categories | Estimated fee (VNĐ) |
| Small Businesses / New Foreign Direct Investment (FDI) | <50 billion | File Appendices 01 and 02; Prepare the basic National File (Local File). | 15,000,000 – 25,000,000 |
| Medium-sized enterprises | 50 - 200 billion | In-Depth Local File Analysis + Benchmarking. | 30,000,000 – 55,000,000 |
| Large Companies / Multinational Corporations | >200 billion | Local File + In-Depth Global File (Master File) | 60,000,000 – 180,000,000 |
| Benchmarking Package (if the business self-reports) | Depending on the scale | Provide data from Orbis/Bloomberg for one industry. | 20,000,000 – 40,000,000 (Depending on the company’s revenue) |
Price Quote for Affiliate Marketing Services Tailored to Specific Industry Sectors
Each industry has a different cost structure, operating model, and level of reliance on related-party transactions, leading to significant differences in profit margins as well as in the complexity of analyzing financial statements. For this reason, pricing for related-party transaction services cannot be based on a single, uniform rate but must be tailored to the specific characteristics of each industry. The table below helps businesses better understand the scope of work and corresponding costs for each industry:
| Industry | Characteristics | Content | Estimated Price |
| Manufacturing – Contract Manufacturing | Profit margins are significantly affected by production quotas | Analysis of Material Costs, Equipment Depreciation, and Labor Fluctuations | Starting at 35,000,000 VND |
| Trade – Distribution | Profit margins depend on the market and the supply chain | Analysis of Gross Profit Margin and the Degree of Homogeneity in the Consumer Market | Starting at 25,000,000 VND |
| Technology and Services | High complexity due to the involvement of intangible assets and internal transactions | Analysis of Royalty Fees, Brand Fees, and Corporate Management Costs | Starting at 45,000,000 VND |
Please note that the prices listed above are for reference only and are subject to change depending on:
- Business size
- Number of related transactions
- The complexity of the case
- Requirements for International Comparative Data
The quoted prices for affiliated transaction services above are for market reference only. For an absolutely accurate fee quote, please contact MAN – Master Accountant Network for consultation and a preliminary assessment of your company’s financial situation and organizational structure.
The Importance of Benchmarking and 5 Pricing Methods
In a standard transfer pricing documentation package, the most important components are the benchmarking data and the selection of the appropriate method.
Benchmarking Data: A Shield for Businesses
During an audit, the tax authority will compare your profit margin with that of other businesses in the same industry. If your data is not reliable, you will completely lose your ability to defend your position.
- Data Sources: Under no circumstances should you use unsubstantiated data you have found on your own. You must use professional databases recognized globally and by the General Department of Taxation, such as Orbis, Amadeus, and Bloomberg, or data from reputable stock exchanges. Access to these sources is very expensive, which is why the pricing for connected trading services from reputable providers is typically higher but ensures security.
- Similarity: The data must satisfy five criteria for similarity: product characteristics, operational functions, contractual terms, economic conditions, and business strategy.
Details on the 5 methods for determining prices in accordance with regulations
Choosing the wrong method can render the entire documentation effort meaningless:
- Comparable Unrelated-Party Price (CUP) Method: A direct comparison of product prices between related and unrelated parties. This method is difficult to apply if the products are not exactly the same.
- Resale Price Method: The price charged to an independent party, minus an appropriate gross profit margin. Typically used for pure distributors.
- Cost-Plus Method: Calculate the cost plus a markup percentage based on the cost. Suitable for manufacturing and contract manufacturing businesses.
- Net Profit Margin (NPM) Comparison Method: The most common method in Vietnam. It compares a company’s profit margin relative to its revenue or expenses with that of independent comparables.
- Profit Split Method: Applied to particularly complex transactions in which all parties contribute unique intangible assets.
There are enormous risks involved if you choose the wrong consulting firm or focus solely on low prices
There are currently many companies in the market that offer to prepare documentation at extremely low rates for affiliate transaction services. Businesses should be aware of the following risks:
- “Fudged” data: Using nonexistent or defunct companies for comparison to force the numbers to match. This is very easy for the tax agency's AI to detect.
- Lack of Ability to Defend the Case: A well-presented dossier on paper is not enough. What matters most is whether, when working with the inspection team, the consulting firm has the expertise and experience to defend the positions outlined in the proposal. Low-cost firms often simply “sell the proposal” and cut off communication when problems arise.
- Discrepancies in the data: Appendix 01 of the tax return does not match the data in the Local File. This is a basic error, but it causes the most severe damage.
Note: Think of the quote for affiliate transaction services as an insurance premium. A competent firm with hands-on experience can help your business save billions of dong in back taxes down the road.
Reference: Related party transaction advisory services
A Standard 6-Step Professional Implementation Process
To ensure the highest level of accuracy in the documentation, MAN—Master Accountant Network—follows a rigorous process:
- Step 1 – Risk Review: Review all related-party transactions that occurred during the year to identify “sensitive” pricing issues.
- Step 2 – Determine the optimal approach: Select one of the five approaches that best fits the client’s business model.
- Step 3 – Search for comparable data: Retrieve data from global financial systems to determine market profit margins.
- Step 4 – Prepare the pricing documentation: Finalize the Local File, Master File, and accompanying appendices in accordance with the Ministry of Finance’s prescribed forms.
- Step 5 – Adjustment Advisory (if applicable): If the profit falls outside the market range, MAN’s transfer pricing team advises on legitimate technical measures to optimize the tax position.
- Step 6 – Assistance with Audit Explanations: Work directly with the tax audit team to defend the reported figures.
Conclusion: Investing in the Sustainability of Foreign-Invested Enterprises
Tax optimization through related-party transactions must go hand in hand with legal compliance. A reasonable quote for related-party transaction services is not just a financial figure; it is a commitment to the legal soundness of the company’s entire accounting system.
Don’t let small mistakes lead to major losses. With a team of experts boasting over 30 years of experience and a high-quality benchmarking system, MAN – Master Accountant Network is confident in being your business’s most trusted partner.
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 Quotes for Affiliate Marketing Services
Fees vary depending on access to specialized databases (Orbis, Bloomberg), as well as practical reporting skills and experience.
Yes, this is a key area of scrutiny. Loss-making businesses must prepare documentation to determine the arm’s-length price of related-party transactions to prove that the loss resulted from objective market factors rather than transfer pricing. If no supporting documentation is provided, the tax authority has the right to assess profits based on the industry average.
Benchmarking data provides factual evidence regarding the profit margins of comparable independent businesses. The tax authority will use this data for comparison. If the benchmarking data is weak or inaccurate, the company’s entire transfer pricing justification will be rejected, leading to a tax assessment.
Businesses must complete their pricing documentation (Local File, Master File) before filing their corporate income tax return (typically 90 days after the end of the fiscal year). These files must be retained by the business and provided to the tax authorities within 15 business days upon request for an audit.
The greatest risks are that the comparative data is not sufficiently reliable and that there is a lack of support when explaining the facts. Low-cost service providers typically only provide basic documentation templates without the ability to defend professional positions before the audit team, leaving businesses at risk of facing massive back taxes.Why are there such large differences in pricing for affiliate marketing services among different providers?
Do FDI enterprises that consistently operate at a loss need to prepare related-party transaction documentation?
Why does benchmarking data determine 90% the success of the application?
When is the deadline for submitting and retaining records used to determine the price of related-party transactions?
What is the biggest risk when a business chooses a consulting firm that offers low service rates?