Consulting services regarding Decree 132 are becoming a mandatory "shield" for businesses with related-party transactions in 2026, as tax authorities intensify inspections using Big Data and AI. Even a small error in identifying related parties, declaring interest expenses, or preparing Local File/Master File records can lead to tax assessments, back taxes amounting to billions of dong, and late payment penalties. This article will help businesses understand the key risks involved. Decree 132/2020/ND-CP, This section discusses the practical difficulties in compliance and why choosing professional consulting services for Decree 132 is the optimal solution to protect cash flow, minimize inspection risks, and build a safe and compliant related-party transaction profile.
Current status of related-party transaction tax management in 2026
2026 marks a turning point as the General Department of Taxation of Vietnam completes its Big Data system and applies artificial intelligence (AI) to review related-party transactions. Transfer pricing discrepancies will no longer easily slip through the cracks. Many FDI enterprises and domestic corporations have faced in-depth audits, resulting in tax arrears amounting to hundreds of billions of dong.
Why does Decree 132/2020/ND-CP remain a persistent problem after years of implementation? The answer lies in the complexity of the law and the shortage of specialized personnel within businesses. Without support from a competent consulting service provider specializing in Decree 132, businesses can easily fall into tax assessment traps due to errors in declaration and documentation. Currently, inspection teams not only examine figures but also delve into the economic nature of transactions, requiring consulting services specializing in Decree 132 to have a multifaceted perspective on both the law and business practices.
Overview of Vietnam's Tax Policy and Decree 132/2020/ND-CP
To understand why tax authorities are tightening their regulations so much, businesses need a comprehensive overview of the current legal system. Fulfilling tax obligations is not simply about paying the full amount, but also about strictly adhering to international principles that have been incorporated into domestic law.
Overlapping tax laws in Vietnam
The tax policy system in Vietnam is known for its complexity and rapid changes. Businesses not only have to comply... Tax Administration Law No. 38/2019/QH14 Furthermore, businesses must have a thorough understanding of the Corporate Income Tax Law and especially Decree 132/2020/ND-CP. The overlap between these regulations creates legal "grey areas" that, without proper understanding, will cause significant difficulties for businesses in explaining matters to regulatory authorities. A quality consulting service on Decree 132 will help businesses connect these documents into a consistent compliance system.
Identify Related Parties
One of the most common mistakes that leads to penalties for businesses is failing to properly identify related parties. According to Article 5 of Decree 132/2020/ND-CP, related parties are not limited to capital ownership but also include relationships related to management, control, or direct/indirect financial support.
- Borrowing: A business borrowing from another business accounts for 25% or more of the owner's equity and over 50% of the total value of medium and long-term debt. This is the point that consulting services regarding Decree 132 often have to warn about the most, because businesses often mistakenly believe that borrowing from individuals or unrelated partners does not count as affiliated companies.
- Management and Control: One business directly or indirectly manages and controls the production and business operations of another business through its key personnel.
- Family: Relationships between individuals with blood ties or marital ties in business operations will be subject to close scrutiny by tax authorities in 2026.
Utilizing consulting services related to Decree 132 will help businesses review their entire organizational chart and cash flow to accurately identify these relationships from the beginning of the fiscal year, avoiding the omission of important related parties.
Arm's Length Principle
This is a core principle stipulating that related-party transactions must have the same value as transactions between independent entities. If internal service fees are unusually high, the consulting service under Decree 132 will need to conduct comparative analyses to demonstrate their reasonableness before the tax authorities intervene.
Practical barriers and difficulties that hinder businesses.
Clause 3, Article 16 of Decree 132 stipulates that the total deductible interest expense shall not exceed 30% of EBITDA. During the period of 2025-2026, when interest rates are highly volatile, this regulation becomes a tremendous financial burden. Many businesses, despite reporting profits on their accounting statements, have to pay very high corporate income tax due to the exclusion of interest expenses.
Without an optimal plan from a Decree 132 consulting service, the additional tax payable could be significantly higher. Experts from MAN – Master Accountant Network's Decree 132 consulting service will help businesses calculate the most legal and optimal way to carry forward interest expenses to later periods (up to 5 years).
Pressure to comply with records at 3 levels
Decree 132 requires businesses to create and maintain the following:
- Local File: Details of transactions in Vietnam.
- Global corporate profile (Master File): Information on the global business model.
- Country-by-Country Profit Reporting (CbCR): For large corporations.
A lack of data and expertise in translating parent company reports is often a weakness of in-house accountants. Consulting services under Decree 132 act as a bridge, ensuring consistent information flow between subsidiaries in Vietnam and the parent company, preventing data conflicts during international tax audits.
Difficulty in finding benchmark data.
To demonstrate that transaction prices are reasonable, businesses need data from comparable independent businesses. The lack of access to copyrighted international databases is a major obstacle. Professional consulting firms specializing in Decree 132, such as MAN, often possess copyrighted data accounts to protect their clients' interests.
The risks are immense when one lacks understanding of tax laws and regulations.
A lack of knowledge or a disregard for regulations regarding related-party transactions will lead to:
- Tax assessment: The tax authorities have the right to reject a company's self-prepared tax return if there is no convincing comparative evidence. In such cases, the assessed tax rate, based on the industry's average profit margin, is often very high. Consulting services under Decree 132 will help businesses build data defenses from the outset.
- Penalties for violations and late payment: A penalty of 20% for the unpaid tax and a late payment fee of 0.03%/day is too high a price to pay. A consulting service package on Decree 132 costs significantly less than the total fines that businesses have to bear.
- Reputation and tax rating risks: When facing large audits and tax arrears, a company's reputation suffers, creating obstacles when dealing with banks or participating in tenders.
Reference: Related party transaction advisory services
Comprehensive solutions from MAN – Master Accountant Network's Decree 132 consulting service.
MAN's process for implementing consulting services on Decree 132 of 2026 is designed to maximize protection of business interests:
- Step 1 – Risk Assessment: Team Transfer pricing consultancy A comprehensive review of all transactions that occurred during the year will be conducted.
- Step 2 – FAR Analysis (Function, Assets, Risks): Clearly identify the role that the entity in Vietnam plays in order to apply the appropriate valuation method.
- Step 3 – Benchmarking Study: Use real-world data to find a safe profit margin (compare with competitors in the same industry).
- Step 4 – Create a profile Completion: This is the core product of the Decree 132 consulting service, ensuring compliance with all requirements from the Tax authorities.
- Step 5 – Data Protection: We support our clients throughout the entire audit explanation process.
Latest price list for consulting services under Decree 132 (2026)
MAN – Master Accountant Network offers flexible solution packages to suit businesses of all sizes. Below is a price list for reference regarding Decree 132 consulting services:
| Category | Implementation content | Estimated fee (VNĐ) |
| Review Package and Declaration | Review transactions, assist with tax declaration. Appendix to Related Party Transactions. | 25,000,000 – 45,000,000 |
| Create a Local File | Conduct economic analysis, find comparative data, and prepare detailed reports. | 80,000,000 – 140,000,000 |
| Create a Corporate Master File | Standardize information from the parent company in accordance with Vietnamese regulations. | 90,000,000 – 160,000,000 |
| Country-to-Country Profit Report | Applicable to large corporations (>18 trillion VND), with global data synchronization. | Pricing is based on the scale and complexity of the transaction. |
| Comprehensive Consulting Package | Complete package including 3 levels of documentation and annual tax optimization consultation. | 180,000,000 – 350,000,000 |
| Support for tax inspectors | Provide direct justification and defense for interest expense and transfer pricing. | Contact for agreement |
Note: The price list is for reference only. To receive an accurate quote for consulting services under Decree 132, please provide your balance sheet and a list of related parties.
Conclusion: Don't let tax risks hinder your business.
Choosing a reputable consulting service for Decree 132 is key to allowing you to focus on your core business activities with peace of mind.
Don't wait until you receive an inspection notice to look for solutions. Thorough preparation through consulting services on Decree 132 starting today will help businesses save billions of dong in taxes and build a professional image of compliance with the law.
Contact Contact MAN's team of transfer pricing experts today for a completely free survey and assessment of related-party transaction tax risks!
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 Decree 132 Consulting Services
To help your company understand better, MAN has compiled the most frequently asked questions below:
Decree 132 applies to all businesses that have transactions with related parties, regardless of size or type. Besides FDI enterprises, domestic companies that borrow capital from related companies, engage in internal buying and selling, share management personnel, or have family relationships in management may also be subject to declaration requirements.
Yes. The obligation to declare related-party transactions depends on whether a related-party relationship and transaction occur, regardless of whether the business is profitable or loss-making. Even if the business has no revenue or has been losing money for many years, it must still submit the appendices according to Decree 132 on time.
Loans from directors or shareholders may be considered related-party transactions if they meet the conditions in Article 5 of Decree 132, especially when the loan accounts for 25% or more of the owner's equity and exceeds 50% of total medium and long-term debt. This is the most common error businesses overlook when declaring assets.
Businesses in Vietnam are still required to provide both a Global Master File and a Local File. However, the Master File can be from the parent company, but it must be translated into Vietnamese and adapted to comply with specific regulations in Vietnam.
During audits, tax authorities typically focus on three key areas: identifying the correct related party, the reasonableness of interest expense, and the appropriateness of profit margins compared to independent businesses in the same industry. Lack of comparative data or inconsistent explanations in records often leads to significant tax arrears.Which businesses are covered by Decree 132?
Do businesses that don't generate profit still have to declare related-party transactions?
Is borrowing money from a director or shareholder considered an related-party transaction?
If the parent company overseas already has a Global Profile, does the company in Vietnam need to create one again?
What aspects do tax authorities typically focus on when inspecting compliance with Decree 132?