The Vietnamese tax authorities have officially adopted artificial intelligence (AI) and big data analytics systems to review related-party transactions. In particular, the implementation of the Global Minimum Tax Policy (Pillar Two) has tightened regulations on FDI enterprises and multinational corporations. Compliance with transfer pricing regulations is no longer an option but a necessity to avoid huge penalties and additional tax burdens.
The question for managers is: What is the current cost of transfer pricing advisory services? Why does Pillar Two cause service fees to trend upwards, yet it's considered a necessary investment to protect businesses?
Pillar Two: Why has transfer pricing risk skyrocketed?
2026 marks the beginning of the aggressive implementation of Pillar Two in Vietnam. This policy stipulates a minimum corporate income tax rate of 15% for multinational corporations with consolidated revenue of 750 million Euros or more. This completely changes the equation regarding transfer pricing advisory service costs, as businesses now face not only... Decree 132/2020/ND-CP, Decree 20/2025/ND-CP Amendments and additions are based not only on Decree 132 but also on new international standards.
The close relationship between Transfer Pricing and Pillar Two
Previously, businesses could engage in transfer pricing to shift profits to countries with low tax rates. However, with Pillar Two:
- Minimum Domestic Additional Tax (QDMTT): Vietnam has implemented this mechanism, meaning that if a company's actual tax rate falls below 15% due to tax incentives, the company must pay the difference within Vietnam. This makes the declaration of transfer pricing advisory service fees more sensitive than ever.
- Double risk: Tax authorities will more closely monitor related-party transactions to ensure profits in Vietnam are not unfairly eroded, and will also compare country-by-country reporting (CbCR) data to determine minimum tax obligations.
Therefore, the 2026 transfer pricing documentation requirements demand absolute accuracy and global consistency. This directly leads to the need for businesses to find a reputable firm to provide appropriate transfer pricing consulting service quotes that are focused on the core issues of the business and build a solid defense strategy.
Why is there such a large difference in the cost of transfer pricing advisory services?
In reality, the cost of transfer pricing advisory services is not the same as regular tax accounting packages. Transfer pricing advisory services are specifically tailored for businesses with related-party transactions, FDI companies, and multinational corporations. The core elements are as follows:
Complexity of the document type
According to Decree 132/2020/ND-CP and the latest guiding circulars on global minimum tax rates:
- Filling out the Appendix: This is a basic form-filling step, but it needs to be cross-checked with the Pillar Two report.
- Local File: In-depth FAR (Function, Asset, Risk) analysis in the context of a volatile supply chain. Creating the Local File accounts for a significant portion of the total cost of transfer pricing advisory services.
- Master File: Requires information connectivity with global consolidated financial reports, ensuring there are no data discrepancies between countries.
Cost of comparative data (Benchmarking Study)
This is considered the "heart" of the document. To prove that the transaction price is objective, the provider... related party transaction advisory services Reputable and experienced firms must purchase data from reputable organizations such as Bureau van Dijk (Orbis/Tp-catalyst) or Thomson Reuters. Maintaining these databases is extremely expensive, often accounting for up to 40% in the cost of transfer pricing advisory services provided by professional firms.
Updated transfer pricing advisory service fees.
Below is an estimated fee structure for businesses with related-party transactions in the context of the global minimum tax rate (Pillar Two), helping businesses better visualize the cost of transfer pricing advisory services. Below is a table of reference transfer pricing advisory service costs, making it easier for businesses to track and budget accordingly.
| Service categories | Scope of work | Estimated cost (VND) |
| Compliance declaration package | Prepare Appendices I, II, III, and IV to accompany the corporate income tax return. | 25,000,000 – 40,000,000 |
| Create Local File Profile | Economic analysis, benchmarking, and detailed reporting in accordance with Decree 132. | 55,000,000 – 110,000,000 |
| Create a Master File profile. | Localizing corporate profiles and cross-referencing Pillar Two's global data. | 45,000,000 – 80,000,000 |
| Pillar Two Impact Assessment | Analyze the effective tax rate (ETR) and the associated transfer pricing risks. | 35,000,000 – 65,000,000 |
| Review the file | Assess potential risks before a tax audit. | 30,000,000 – 55,000,000 |
| Inspection Support | The expert defends the records directly before the tax inspection team. | According to the nature of the project. Contact for agreement |
Note: The above transfer pricing advisory service fee does not include VAT and additional benchmarking data purchase fees if the transaction is highly specific.
Cost analysis by scale and industry specifics.
The cost of transfer pricing advisory services needs to be broken down to suit the budget and risks of each type of business:
Small and medium-sized FDI enterprises
This group typically engages in simple transactions such as buying and selling tangible goods or internal borrowing. However, the biggest risk is technical errors in the declaration of the Appendix.
- Estimated cost: From 50 – 90 million VND/year.
- Value received: Ensuring compliance with regulations, avoiding tax audits due to avoidable errors. This is the optimal cost for transfer pricing consulting services to ensure safety.
Manufacturing and Processing Industry
This is a key area for inspection due to fluctuations in raw material and labor costs.
- Complexity: Requires extremely detailed comparative analysis of net profit margins for each product line.
- Estimated cost: Ranging from 100 to 200 million VND. Paying this level of transfer pricing advisory service fee helps businesses explain operating losses due to market fluctuations.
Technology and Intangible Assets Industry
This is a "hot spot" for the global minimum tax policy (Pillar Two), as royalty and software fees are often scrutinized due to the ambiguity in their pricing.
- Challenge: Finding comparable data is extremely difficult, requiring experts to use profit-sharing methods.
- Estimated cost for transfer pricing advisory services: Typically ranges from VND 160 million due to the highly technical nature requiring specialized expertise.
Implementation process and the value behind the cost.
To understand why transfer pricing advisory services are charged at the levels mentioned above, businesses need to look at the in-depth workflow and the actual value received from the expenses incurred:
- Step 1 – Survey and data collection: Analyze the current state of the company's related-party transactions.
- Step 2 – Functional, Asset, and Risk Analysis (FAR Analysis): Determine the business's role within the group's value chain.
- Step 3 – Choosing a pricing method: Select the method that best suits the size and industry of your business.
- Step 4 – Benchmarking: Use international databases to find similar businesses.
- Step 5 – Economic analysis and adjustment: Eliminate differentiating factors to arrive at a standard profit margin.
- Step 6 – Prepare the Report (Local File/Master File): Draft the document in Vietnamese, English, or Chinese (if needed).
- Step 7 – Post-sales support: Assisting you in explaining matters to the tax authorities when required.
The entire process is carried out by a team of transfer pricing specialists in collaboration with the tax team. This ensures that the transfer pricing documentation is highly convincing. That's why the cost of transfer pricing consulting services cannot be too cheap.
Reference: Related-Party Transaction Reporting Service.
The “hidden” factors that change the value of consulting contracts.
Don't just choose a firm based on the lowest quote; consider the factors that affect the quality and cost of transfer pricing consulting services:
- International compatibility: Does the consulting firm have the capacity to ensure that the data in Vietnam matches the group's reports abroad?
- Comparative data quality: Is the data extracted from copyrighted sources or is it pirated data? This directly affects the legal validity of the application and poses future risks.
- Scope of protection: Ensure that the transfer pricing advisory service fee you pay includes the cost of support when a tax audit team conducts an on-site inspection.
A direct look at costs and financial security.
Many businesses try to prepare their own transfer pricing documentation to save on consulting fees. However, without standardized comparative data, the documentation will be immediately rejected during an audit. This is not saving money, but risk.
A low-cost service often provides empty reports, lacking relevant comparative data and high credibility. Therefore, the documentation is easily rejected by authorities. Essentially, the business is only paying for a facade that offers no protection against tax authorities. The truth is, the cost of transfer pricing consulting services always reflects the quality, value of the data, and expertise of the professionals.
MAN – Master Accountant Network understands the pressure faced by finance professionals when explaining expenses. However, investing in professional transfer pricing advisory services is how businesses can protect their reputation and ensure long-term stability.
Conclude
In summary, under pressure from the Global Minimum Tax Rate (Pillar Two), paying for reasonable transfer pricing advisory services is a necessary expense for risk management. Investing in a standardized set of documentation will help businesses avoid penalties, back taxes, and even tax assessments.
Contact MAN – Master Accountant Network for expert support and free consultation!
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 is moderated by: Mr. Le Hoang Tuyen – Founder & CEO of Man, CPA Vietnam Auditor with over 30 years of experience in Accounting, Auditing and Financial Consulting.
Frequently Asked Questions about Transfer Pricing Advisory Service Fees
Typically, transfer pricing advisory services fees include the fee for a risk analysis expert (FAR), fees for purchasing benchmarking data from international organizations (such as Orbis), and fees for preparing Local File/Master File documents. Reputable firms like MAN will also include fees for assisting with explanations during on-site tax audits.
Pillar Two requires absolute consistency in earnings reporting between Vietnam and global reporting. Therefore, transfer pricing advisory service fees typically increase by 20-30% due to the additional tasks of domestic minimum tax reconciliation (QDMTT) and country-by-country profit reporting (CbCR).
No. Businesses with losses and related-party transactions are subject to stricter control. Paying transfer pricing advisory fees is now mandatory to demonstrate that the losses arose from objective market factors, preventing the tax authorities from assessing profits and collecting back corporate income tax.
Comparative data must be extracted from copyrighted databases, ensuring objectivity as required by the OECD and Decree 132. This is the only legal evidence to protect profit margins. Therefore, this fee always accounts for approximately 30-40% of the transfer pricing advisory service costs.
Low-cost services often lack standardized comparative data or sound reasoning. During audits, tax authorities can easily dismiss records and arbitrarily determine profit margins. Small initial savings can lead to billions of dong in fines, far exceeding the cost of transfer pricing consulting services from reputable, experienced firms.
Businesses should sign contracts in the second or third quarter of each year. Early implementation allows the consulting firm sufficient time to gather clean data, thereby optimizing transfer pricing consulting service costs and minimizing pressure close to the tax settlement deadline.What are the costs included in transfer pricing advisory services?
How does Pillar Two affect the cost of filing related-party transactions?
Are loss-making businesses exempt from filing the necessary documents?
Why do benchmarking fees account for such a large proportion of total service fees?
Why shouldn't you hire a cheap transfer pricing consultant?
When is the best time to negotiate transfer pricing advisory service fees?