Transfer pricing services are becoming an urgent need for FDI businesses in Vietnam in 2026, as tax authorities intensify inspections and the global Business Performance Indicators (BEPS) trend tightens. Many businesses face the risk of heavy tax assessments and back taxes due to transfer pricing documentation lacking legal basis, or complex transfer pricing reporting processes that consume significant internal resources.
With over 30 years of experience advising on tax and transfer pricing for hundreds of multinational corporations, MAN – Master Accountant Network confidently provides comprehensive transfer pricing services, ensuring compliance. Decree 132/2020/ND-CPThis optimizes legal tax costs and completely eliminates the risk of tax assessment, helping businesses confidently develop sustainably.
What is transfer pricing service?
Transfer pricing services are in-depth consulting solutions designed to assist businesses in preparing and completing Transfer Pricing Documentation in accordance with tax laws. This is a mandatory set of documents for businesses with related-party transactions, used to demonstrate that the prices applied in internal transactions comply with the arm's length principle when requested by the tax authorities.
Simultaneously, transfer pricing risk is a concern that businesses with domestic and international connections need to pay special attention to when determining prices for transactions such as buying and selling goods, providing services, transferring tangible and intangible assets, lending, borrowing, or other internal financial activities. Failure to properly control transfer pricing risk can lead to many adverse consequences, including:
- Loss of taxable income and tax liability due to profits being transferred to countries or regions with low tax rates or tax incentives.
- There is an increased risk of being audited by the tax authorities, having taxes assessed, and being subject to back taxes along with penalties and late payment fees due to non-compliance with regulations on related-party transactions.
- Legal disputes can arise, affecting the company's reputation and relationships with partners and regulatory agencies, as well as its brand image in the market.
The documentation for determining transfer pricing needs to be built on a foundation of complete and systematic information, including:
- All data relating to transactions arising between the business and its related parties;
- Describe the organizational structure, operating model, and management chart of the business;
- Provide detailed explanations of related-party transactions arising during the reporting period, including the nature and value of the transactions;
- Comparative information from similar transactions between independent parties in the market.
Therefore, transfer pricing services are specialized solutions to assist businesses in collecting, analyzing, and completing transfer pricing documentation in accordance with tax laws.
The most common forms of transfer pricing today.
Related party transactions requiring transfer pricing management are diverse and are often classified according to the transaction object:
- Transfer pricing through goods: This is the most common form, typically the purchase and sale of raw materials and finished products between companies in the group at prices not following the market (For example: Setting input prices too high or output prices too low to transfer profits).
- Transfer pricing through services (Services): Management fees, technical support fees, internal service fees are calculated not based on the principle of independent transactions, or charged for services that have no real value.
- Financing: Interest rates on loans, guarantees, or cash management fees between related parties are set abnormally high or low compared to independent market rates.
- Transfer pricing through intangible assets (Intangibles): The valuation, use or transfer of brands, patents, and technological know-how between related parties is not transparent. This is the most complex form of transfer pricing management, requiring high expertise.
See details: Details of the various forms of transfer pricing in businesses.
When do businesses need to prepare transfer pricing documentation?
All businesses that engage in related-party transactions (buying and selling goods, lending, management fees, royalties, etc.) must comply with the following:
- Complete Form 01: Attached to the annual Corporate Income Tax Return.
- Establish a three-level documentation system: Stored within the company and presented within 15 working days upon inspection request.
Filing a profile is a necessary condition. But which category a business belongs to is the deciding factor in whether or not it will be considered. Let's find out with MAN below.
Which groups of businesses are currently under scrutiny by tax inspectors?
In Official Letter No. 12454/BTC-TTr issued by the Ministry of Finance on October 29, 2021, concerning the development and implementation of the financial inspection and audit plan for 2022 and subsequent years, the Ministry of Finance clearly identified the groups of enterprises subject to enhanced supervision, inspection, and auditing. This is especially important during the period leading up to 2026, when the State focuses on digital transformation, and includes the following entities:
- Businesses with high tax risks;
- Businesses are entitled to tax exemptions and reductions.
- Businesses are transferring projects, brands, and capital.
- The company operates in new and specialized business sectors;
- Organizations and businesses in the banking and finance sector;
- Foreign-invested enterprises engage in transfer pricing activities.
- Businesses import goods with high trade value and high tax rates;
- Businesses import raw materials to process for foreign companies or to produce goods for export.
- Export processing enterprises;
- Businesses operate on digital platforms, through e-commerce.
Once a business is under scrutiny, any transfer pricing errors can become a risk for tax recovery and assessment.
The high cost of transfer pricing violations.
Businesses shouldn't wait until it's too late to take action. According to Decree 125/2020/ND-CP and Decree 132/2020/ND-CP, the consequences of incomplete transfer pricing documentation are not just financial losses, but the very survival of the business:
Risks of tax assessment and anti-collection efforts.
If there is no valid transfer pricing documentation or the pricing method is rejected, the Tax Authority has the right to determine the profit margin based on its own data.
- Consequences: Businesses may be subject to a net profit margin of 5% – 15% on revenue, even if they are actually operating at a loss. This leads to a sharp and uncontrollable increase in corporate income tax payable.
The fines are "staggering".
Specifically, businesses may be subject to the following charges simultaneously:
- Administrative penalties: Up to 20% for the amount of tax underpaid or the amount of tax exempted, reduced, or refunded in excess of regulations.
- Late payment penalty: Calculated at a rate of 0.031 TP3T/day on the amount of tax overdue. Imagine a tax arrears from 3-5 years ago; this interest could be equivalent to the original tax amount.
- Penalties for procedural violations: Fines ranging from 8 to 25 million VND will be imposed for each violation of failing to declare or incompletely declaring related-party transaction forms.
Eliminate interest expenses.
According to Decree 132/2020/ND-CP, if the documentation is not complete, interest expenses exceeding 30% EBITDA will be disallowed as deductible expenses when calculating taxes. This represents a significant financial loss for businesses with high financial leverage.
The process is complex and time-consuming.
Gathering financial data, conducting functional and risk analysis, and selecting independent benchmarks is extremely complex and requires a significant investment of time from the internal team.
Lack of Legal Updates
Transfer pricing regulations are constantly changing in line with global trends (e.g., Global Minimum Tax – Pillar Two), making it difficult for non-specialists to keep up. A small error in applying the law can have big consequences.
Comprehensive solutions from MAN – Master Accountant Network
With over 30 years of experience, MAN doesn't just handle paperwork; we build a "tax shield" for businesses.
- Solution 1 – Protection Against Tax Collection and Assessment: We utilize a proprietary and accurate benchmarking data system to protect your business's pricing methodology against the most stringent scrutiny from tax inspectors.
- Solution 2 – Resource Optimization: Instead of letting the internal team struggle with thousands of pages of data, MAN handles the entire process. Businesses save 80% of time to focus on core business.
- Solution 3 – Legal Updates: MAN is a pioneer in updating global minimum tax regulations applicable from 2024-2026, ensuring that businesses' transfer pricing strategies remain relevant in the face of international legal changes.
- Solution 4: Optimizing Legal Tax Costs: Beyond just compliance, we advise on transaction structures to help businesses maximize tax benefits and intelligently and legally transfer expenses.
MAN's specialized transfer pricing services
MAN's transfer pricing services include the following:
- Prepare transfer pricing reports;
- Consulting services for preparing Transfer Pricing Documentation;
- Transfer Pricing Document Review Service;
- Represent and support your business in transfer pricing inspection.
Procedure for providing and preparing Transfer Pricing Reports 2026
MAN will follow the following procedure for providing transfer pricing reporting services to clients:
Step 1: Gather the business's needs and information.
At this stage, MAN will receive overview data to conduct a preliminary assessment of the company's business performance, including:
- Industry, business sector
- Business tax identification number
- Revenue size (monthly or annually)
- Total investment capital
- Number of personnel currently employed
- Other relevant background information
- It is important that all transactions with related parties are conducted in a related manner.
This data forms the basis for MAN to determine the extent of related-party transactions and potential transfer pricing risks.
Step 2: Conduct in-depth research and analysis of the business model.
After receiving initial information, MAN's team of experts proceeded to conduct a more detailed investigation and analysis of:
- Production and business model
- Organizational structure and relationships
- Industry specifics and operational practices
Simultaneously, MAN will engage directly with businesses to understand their business objectives, compliance requirements, and tax management orientation, thereby accurately determining the appropriate transfer pricing service needs.
Step 3: Propose appropriate and optimal transfer pricing solutions.
Based on the analysis results, MAN develops a separate transfer pricing strategy for each enterprise, ensuring compliance with the law while minimizing tax risks.
Services may include:
- Prepare documentation to determine transfer pricing in accordance with regulations.
- Prepare and review the related party transaction appendix.
- Assess, identify, and correct deficiencies in existing records.
- Consulting services to improve pricing methods that are appropriate to reality.
Step 4: Discuss and send a detailed quotation.
Based on the scope of work, complexity, and specific requirements, MAN will work directly with the company's leadership to agree on a solution and provide a clear and transparent quotation before implementing the service.
Reference price list for transfer pricing services in 2026
The cost of transfer pricing services is not fixed but depends directly on the scope of work and the complexity of the business. Key factors determining the fee include: revenue size, the number and complexity of related-party transactions (goods, services, finance, intangible assets), and whether a Master File or Country-by-Country Report (CbCR) is required.
| Category | Reference cost | Note |
| Basic Package (Country Profile Only) | 40,000,000 – 80,000,000 VND | This applies to small and medium-sized enterprises (SMEs) with only simple related-party transactions (buying and selling ordinary goods or services). |
| Standard Package (Country Profile and Complex Financial Analysis) | 80,000,000 – 120,000,000 VND | Enterprises with large revenue, complex related transactions, requiring in-depth analysis of loan interest rates and management fees. |
| Comprehensive Package (All 3 levels of Transfer Pricing Documentation) | From 150,000,000 or more | For multinational corporations that need to prepare both Master File and CbCR, with transactions involving intangible assets. |
Note: The prices listed above are for reference only and are based on common scenarios. The actual cost of transfer pricing services will be determined based on the scope of work, the number of transactions, and the complexity of the corporation.
What makes businesses trust MAN?
The quality of services provided by MAN – Master Accountant Network is trusted and chosen by many businesses nationwide thanks to the following outstanding advantages:
- A team of transfer pricing experts: MAN brings together highly qualified consultants with in-depth knowledge of transfer pricing and tax law. As a result, the solutions provided are not only compliant with regulations but also highly applicable and suitable for the practical realities of tax audits in Vietnam.
- Multi-sectoral experience: At MAN, our team of experts has directly handled transfer pricing documentation for a wide range of manufacturing, trading, and service sectors. This allows us to develop transfer pricing strategies that are closely tailored to the specific operations, business models, and risk levels of each enterprise.
- Risk mitigation and tax efficiency optimization: MAN supports businesses in proactively controlling risks in related-party transactions, minimizing the possibility of tax arrears, tax assessments, and penalties when tax authorities conduct audits and inspections.
- Throughout the entire process: MAN is committed to supporting businesses in all aspects of transfer pricing, from initial consultation and documentation to providing explanations when requested by tax authorities, helping businesses operate with peace of mind in the long term.
MAN's commitment to businesses regarding transfer pricing services.
Below are MAN's commitments to businesses when providing transfer pricing services:
- Absolute legal compliance: MAN deploys its services based on strict adherence to all current regulations on transfer pricing, proactively identifying and controlling risks arising from related-party transactions.
- Accuracy in every detail: All analyses, calculations, and operations are performed with high precision, ensuring that records truthfully reflect the nature of the business's operations.
Partnering to handle issues: MAN not only prepares documentation but also supports businesses in reviewing, adjusting, and promptly correcting errors during implementation or when requested by the tax authorities. - On schedule: All work is completed on time as agreed, allowing the business to proactively plan its finances and comply with tax obligations.
Conclude
In the context of increasingly stringent tax regulations in 2026, transfer pricing is no longer just a way to "cope with audits" but has become a key factor determining the financial security and sustainability of FDI enterprises. A well-prepared, standardized, and explainable transfer pricing dossier not only helps businesses comply with the law but also proactively control risks and optimize tax costs legally.
With practical experience and a team of experts deeply knowledgeable in both legal regulations and tax audit procedures, MAN – Master Accountant Network is ready to support businesses right from the initial review stage. Early assessment of transfer pricing documents will help businesses identify risks promptly and develop solutions before the tax authorities intervene.
Contact MAN – Master Accountant Network for advice and review of transfer pricing risks, before unnecessary recovery costs and penalties become a burden for your business.
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 Transfer Pricing Services
If no profit is generated, is it still necessary to prepare a benchmarking report?
It's still necessary. Benchmarking isn't just used to demonstrate "high" or "low" profits, but to show that a company's profit (or loss) level is appropriate to market conditions and the actual functions and risks it undertakes.
How long does it take to process transfer pricing documents?
Typically, this takes 15-30 business days, depending on: the complexity, data quality, and scope of comparative analysis required. For urgent cases needing processing for inspection purposes, MAN may prioritize the process.
Does MAN provide support when a business is undergoing a tax audit?
Yes. MAN not only prepares the documentation but also directly participates in explanations, works with the inspection team, and supports businesses in defending their transfer pricing arguments with data and professional reasoning.
Are transfer pricing service fees considered deductible expenses?
Yes, if the service directly supports business operations and is accompanied by a complete contract, invoice, and supporting documents as required. MAN assists businesses in standardizing expense records to ensure validity during tax settlement.
When is the best time to conduct a transfer pricing review?
As soon as related-party transactions occur or before the corporate income tax settlement period, early review helps businesses make timely adjustments, avoiding the risk of being caught off guard when the tax authorities intervene.
Editorial Board of MAN – Master Accountant Network