Transfer pricing advisory services are becoming an important solution to help FDI enterprises and multinational corporations control tax risks in the context of increasingly stringent inspections of related-party transactions by regulatory authorities. The application of these services is becoming increasingly important. Decree 132/2020/ND-CP With increasingly stringent international standards on tax transparency, businesses not only need to properly file transfer pricing documents but also must demonstrate the reasonableness of internal transactions. This article will analyze the overall transfer pricing risks in 2026, common violations that lead to tax arrears and tax assessments, and provide in-depth expert insights. Related party transaction compliance consulting To help businesses build sustainable and secure tax compliance strategies in the face of audits.
The tax season is hotter than ever.
Entering 2026, foreign-invested enterprises (FDI) in Vietnam are facing unprecedented challenges. No longer relying on random audits, tax authorities are now applying artificial intelligence (AI) to analyze profit fluctuations and identify suspicious signs of transfer pricing right from the financial reporting stage.
Integration of interconnected data systems
By 2026, Vietnam will have fully mastered the Automatic Exchange of Information (AEOI) system. This means that all transactions of parent companies abroad, from royalty fees and management fees to input material prices, will be clearly displayed on the screens of Vietnamese tax officials. The 2026 tax season will focus particularly on businesses with "unusually low profits" or accumulated losses but which continue to expand their production scale.
Pressure from the Global Minimum Tax (GMT)
The adoption of GMT (Global Pricing Code) has shaken the traditional transfer pricing structure. Businesses not only face the risk of tax recovery in Vietnam but also must ensure consistency in reporting cross-country profits. This is where the role of transfer pricing consultants becomes essential to help businesses balance domestic tax obligations with international standards.
Why do businesses need transfer pricing advisory services?
In the field of taxation, particularly related-party transactions, the difference between a "compliant" filing and a "rejected" one lies in the depth of the economic analysis.
Professionalism
In Vietnam, Decree 132/2020/ND-CP and Decree 20/2025/ND-CP While the two regulations on related-party transactions remain the guiding principles, supplementary circulars issued in 2025 and early 2026 have introduced stricter regulations regarding evidence proving independence. A professional transfer pricing consulting firm must possess a team with a deep understanding of the economic nature of the transaction, not simply copy data into a template.
Practical experience
Experience is not just measured by the number of years in operation, but by the number of times we have directly presented our case to specialized transfer pricing inspection teams. We have witnessed many businesses that prepare their own documentation, but when questioned by the tax authorities about "functional and risk analysis," internal accountants often struggle due to a lack of comparable data, leading to incorrect tax assessments.
Authority and reliability
The reliability of a transfer pricing record depends heavily on the credibility of the entity. Transfer pricing consultancy. Large corporations always prioritize reputable companies, as this provides the strongest "shield" when entering the tax administration room.
The structure of the documentation for determining transfer pricing is standardized according to regulations.
To prepare for tax season, businesses need to have a firm grasp of the three-tiered documentation system. Missing any component can render the documentation invalid.
Local File
This is the most detailed document, focusing on transactions occurring in Vietnam. It requires a detailed analysis of:
- Organizational chart and business strategy.
- List of related parties and resulting transactions.
- Economic analysis and pricing methods.
Global corporate profile (Master File)
The Master File provides a comprehensive overview of a corporation's global business operations, including internal pricing policies, intangible assets, and intercompany financing agreements. In Vietnam, many FDI businesses often overlook the importance of receiving the Master File only from the parent company without "localizing" it to comply with Decree 132. A professional transfer pricing consulting firm will help businesses review the compatibility between the Local File and the Master File.
Country-by-Country Reporting (CbCR)
For corporations with consolidated revenue of VND 18 trillion or more, CbCR is mandatory. In 2026, the tax authorities will pay special attention to comparing tax data paid in Vietnam with that of countries with low tax rates (tax havens).
The violations resulted in the company being ordered to pay back billions of dong.
Through its transfer pricing consulting services, MAN – Master Accountant Network has compiled the most common mistakes that businesses often make:
Exceeding the interest expense ceiling (30% EBITDA)
Decree 132/2020/ND-CP stipulates that total deductible interest expenses should not exceed 30% of EBITDA. However, many businesses are still confused about determining whether loans from banks fall under the category of related-party transactions (for example, when a bank lends more than 25% of its equity). Incorrect calculation of this ratio often leads to expenses being disallowed when calculating corporate income tax, causing significant financial losses.
Choosing the wrong comparison method
Many accountants often default to using the net profit margin comparison method (NPMR) due to its simplicity. However, if a transaction is unique and does not use the independent price comparison method (CUP), the tax authorities may reject the entire filing and establish a different set of comparable companies to determine the tax liability.
Deficiencies in the "Benefit Test" analysis for internal services.
When a parent company charges management fees, royalties, or technical support fees to its subsidiary in Vietnam, the subsidiary must provide proof:
- That service was actually provided.
- That service generates profit or economic value for the Vietnamese company.
- The fee is equivalent to the market price. If this evidence (contract, work log, proof of handover) is missing, the entire fee will be completely disallowed by the tax authorities.
- Fixed assets are used in the production and business operations.
Latest price list for transfer pricing consulting services.
To give your company an overview of the investment required for a high-quality documentation package, below is a table of reference fees based on the scale and complexity of the related-party transaction. Please note that these are prices for related party transaction advisory services professional, This includes access to international databases and accountability support.
| Category | Size/Transaction | Price (VNĐ) | Completion time |
| Benchmarking Study Package | Under 3 simple affiliate transactions | 25,000,000 – 45,000,000 | 5-7 days |
| Create a Local File | Revenue under 200 billion and simple transactions | 60,000,000 – 90,000,000 | 10-15 days |
| Create a Local File | Revenue of 200-1000 billion, diversified transactions. | 100,000,000 – 180,000,000 | 4-6 weeks |
| Create a Master File | Localization from the Group's original design. | 30,000,000 – 60,000,000 | 7-10 days |
| Complete Transfer Pricing Documentation Package | Local File + Master File + Appendix | 120,000,000 – 250,000,000 | 6-8 weeks |
| Review and support for audit explanations | Based on the facts of the case/scale of the inspection | Contact for agreement | According to tax schedule |
Note: The above price list is for reference only. The actual cost of transfer pricing advisory services will depend on the number of comparable companies to be searched, the specific nature of the industry, and the volume of financial data to be processed.
Potential risks from "cheap," unreliable transfer pricing advisory services.
Currently, the market is flooded with individuals and companies offering transfer pricing consulting services at extremely low fees, only 1/3 or 1/5 of what other providers charge. related party transaction advisory unit Professionalism is a dangerous "trap" that businesses with related-party transactions need to be extremely aware of.
The resume is "empty" and lacks depth.
Low-cost services often use pre-made templates and do not perform actual benchmarking on databases like Orbis or Moody's; instead, they often fabricate figures. When audited, these figures quickly reveal flaws in the data-scanning tools of the tax authorities.
The "disappearance" during the actual inspection.
A characteristic of unreliable consulting firms is that they are only responsible for preparing the documentation but do not commit to accompanying the business during the explanation phase. Meanwhile, the tax audit process usually takes place 3-5 years after the documentation is prepared. By then, the low-cost consulting firm may have dissolved or refused to provide support because their "contract has expired".
Tax assessed and late payment penalties imposed.
When the application is rejected, the tax authorities have the right to use their data to determine the profit margin. At that point, the additional tax payable, plus late payment penalties (0.031 TP3T/day), will be hundreds of times the amount the business "saved" from hiring the cheap service.
Think of transfer pricing advisory fees as insurance for your business's profits. A solid record keeps your business safe during each tax season.
The process for implementing professional transfer pricing advisory services at MAN.
To ensure the utmost accuracy and confidentiality for our clients, our workflow is standardized according to the following steps:
Step 1: Review the relationship and identify the transaction.
MAN – Master Accountant Network conducts on-site surveys at businesses, reviewing accounting records and contracts to accurately identify the list of affiliated parties. In many cases, businesses are unaware of their affiliated relationships until MAN experts point them out.
Step 2: Functional, Asset, and Risk Analysis (FAR Analysis)
This is the "heart" of the transfer pricing profile. We conduct an in-depth analysis of the company's function in Vietnam (manufacturing, processing, or distribution?), what assets it owns, and what risks it faces. From there, we build a suitable economic risk profile.
Step 3: Search for and select benchmark data.
Using global data systems, we search for independent companies with similar functions to establish an “arm's length range.” MAN ensures that comparable companies are carefully selected based on geography, size, and industry.
Step 4: Prepare the documentation and declare the Related Party Transaction Appendix.
We assist businesses in completing the Appendices according to the mẫu prescribed in Decree 132/2020/ND-CP to submit with the corporate income tax return. All figures in the related-party transaction documents and financial statements must ensure absolute consistency.
Step 5: Assisting with explanations and defending the case file.
We are committed to supporting businesses until the end of the tax audit. Our experts will directly engage with the audit team, presenting strong economic arguments to defend the business's pricing strategy.
Why choose transfer pricing advisory services from MAN – Master Accountant Network?
Among hundreds of companies on the market, MAN proudly offers something different thanks to:
- Expert team: Comprising former senior executives from the Big4 firms and tax consultants with over 25 years of experience.
- Accurate data: Ensuring that comparison data is always up-to-date and accurate.
- Strategic thinking: We don't just prepare documents; we advise on how to restructure related-party transactions to legally optimize tax compliance.
- Commitment to responsibility: We guarantee absolute confidentiality of information and assume the highest level of responsibility for the legal validity of the documents we prepare.
Conclude
In the context of increasing tax authorities' oversight and the application of big data to detect risks, managing related-party transactions is no longer just a declaration obligation but has become a crucial part of a company's tax management strategy. Strict adherence to the regulations in Decree 132/2020/ND-CP, the preparation of complete transfer pricing documentation, and the establishment of transparent internal pricing policies will help businesses minimize the risk of tax assessments, back taxes, and penalties during audits.
However, in reality, many businesses still struggle with function-asset-risk (FAR) analysis, finding comparative data, and building compelling economic arguments. Therefore, consulting with specialized transfer pricing advisory services like MAN will help businesses proactively identify risks, standardize documentation, and build a sustainable tax compliance strategy from the outset.
If your business is engaging in related-party transactions or wishes to review its transfer pricing records, contact Collaborate with MAN – Master Accountant Network to conduct early risk assessments. A well-structured transfer pricing management strategy not only provides businesses with peace of mind during tax audits but also creates a solid foundation for long-term market growth.
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
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 Advisory Services
Which businesses are required to prepare Transfer Pricing Documentation?
According to Decree 132/2020/ND-CP, businesses that have transactions with related parties (ownership, management, or control relationships) during the tax period must declare them. Except for cases exempted from filing under Article 19, businesses must prepare a three-level set of documents (Local File, Master File, CbCR) to prove the independence of the transaction price.
What obstacles do businesses face when preparing transfer pricing documents themselves without consulting experts?
The biggest obstacle is having your application rejected by the tax authorities due to a lack of benchmarking data or inaccurate functional analysis (FAR). In such cases, the authorities have the right to determine the profit margin based on industry data, leading to the collection of back taxes and late payment penalties at significant cost.
Which entities are subject to the 30% EBITDA interest expense cap?
This regulation applies to businesses with related-party transactions. Total deductible interest expense (after deducting interest on deposits and loans) incurred during the period shall not exceed 30% of total net profit from business operations plus interest expense and depreciation expense. Any expense exceeding this limit shall be carried forward to the next period for 5 years.
Why is it necessary to localize the Global Corporate Profile (Master File)?
Many FDI businesses only use the original Master File from their parent company, but this often does not fully meet the structure and language requirements stipulated by Vietnamese regulations. Localization helps to compare the compatibility between global pricing policies and operational realities in Vietnam, avoiding data discrepancies when explaining to inspection teams.
How important is Benefit Testing in internal services?
The tax authorities place particular emphasis on scrutinizing management and technical fees paid to the parent company. Businesses must provide evidence demonstrating that actual services were provided, that the fees were in line with market prices, and that they directly generated economic value. If the benefits cannot be proven, the entire expense will be disallowed.
How will the AEOI system affect transfer pricing audits in 2026?
The Automatic Exchange of Information (AEOI) system helps Vietnamese tax authorities transparently access financial data from parent companies and their overseas subsidiaries. This interconnectedness makes it easier to detect profit shifting to low-tax countries through comparisons of profit margins across countries.
What support does MAN provide during the tax audit process regarding transfer pricing?
MAN not only prepares the documentation but also assigns experts to work directly with the inspection team. We defend the economic arguments, comparative sampling methods, and demonstrate the reasonableness of the profit margin. This support helps businesses minimize the risk of being overcharged due to a lack of experience in dialogue.