Services complying with Decree 255: Latest update 2026

In the context of tax authorities strengthening controls on transfer pricing and deploying a big data-driven risk analysis system by 2026, compliance services... Decree 255/2026/ND-CP, This document, which regulates tax management for related-party transactions of enterprises with related-party relationships, replaces Decree 132/2020/ND-CP. In reality, even a small error in the documentation can lead to the collection of billions of dong in back taxes, the assessment of profits, and subjection to regular inspections.

This article helps businesses gain a clear overview of risks, stay updated on the latest changes in Decree 255/2026/ND-CP, and choose effective compliance solutions, thereby protecting cash flow, optimizing tax costs, and maintaining business reputation in an increasingly stringent legal environment.

What are the services that comply with Decree 255/2026?

The service in compliance with Decree 255/2026 is a service that assists businesses in preparing documentation for determining transfer pricing, filing taxes, and proving transfer pricing according to the arm's length principle, in line with the current legal framework.

To understand why this service is becoming so urgent, we need to look at how the tax administration landscape is changing dramatically in 2026.

Current status of tax management and inspection of related-party transactions in 2026

2026 marks a turning point in tax administration in Vietnam with the increasingly comprehensive operation of the risk management system. The tax authorities continue to improve the big data system, connecting with countries in the global tax information exchange network, while also applying artificial intelligence to review discrepancies in transaction prices.

Notably, on July 9, 2026, the tax authorities issued a document introducing 10 new points of Decree 255/2026/ND-CP, showing that tax management is gradually shifting from a purely risk-based management model (focusing on detecting violations and conducting inspections and handling them afterward) to a compliance management and compliance support model, with taxpayers at the center.

Businesses often come under scrutiny if they have unusually low profit margins compared to the industry average or incur significant interest expenses from related parties. Many businesses, failing to keep up with new regulations, have inadvertently created loopholes in their records, leading to retroactive corporate income tax collection and being classified as high-risk. Therefore, seeking a professional compliance service that is up-to-date with Decree 255/2026/ND-CP from the beginning of the fiscal year is the safest solution.

However, before addressing the risks, businesses need to properly understand the legal nature of Decree 255/2026/ND-CP.

Legal overview of Decree 255/2026/ND-CP

Decree 255/2026/ND-CP is the current legal document regulating tax management for enterprises with related-party transactions, replacing Decree 132/2020/ND-CP. The Decree is based on international standards on combating base erosion and profit shifting (BEPS), and has been amended and supplemented to ensure consistency with the 2025 Tax Administration Law. Compliance services will help businesses operate based on two core principles:

• The arm's-length principle: Compare the transaction price of a business with the price of unrelated parties under equivalent conditions.
• Substance over form: Tax authorities have the right to reject formal contracts if the economic substance of the transaction is inconsistent, in order to prevent the transfer of profits abroad or to entities with low tax rates.

A notable new point is that the principles applied in Article 3 of Decree 255/2026/ND-CP now directly refer to the principles of tax management and tax inspection stipulated in the 2025 Law on Tax Administration, aiming to ensure consistency and completeness throughout the entire tax legal system.

See also: New points in Decree 255/2026/ND-CP regarding related-party transactions.

Identifying Related Parties under the New Regulations

Identifying the affiliated party remains the first and most important step in compliance services. According to Article 5 of Decree 255/2026/ND-CP, common cases include:

• Ownership of capital: One party directly or indirectly holds at least 25% of the owner's equity.
• Executive authority: One party directly or indirectly manages and controls senior personnel decisions or financial policies.
• Specific loan relationships: This remains a major obstacle for Vietnamese businesses. If a business borrows capital from another entity (including banks) and that loan accounts for at least 25% of the owner's equity and over 50% of the total value of medium and long-term debt, then that lending entity is considered an affiliated party.

Important new points: Decree 255/2026/ND-CP adds a new provision regarding related-party transactions arising from borrowing and lending (not just borrowing and lending as before), applicable to transactions involving the transfer or acquisition of capital contributions of at least 25% of owner's equity, or borrowing, lending, or lending of at least 10% of owner's equity at the time of the transaction, with individuals managing or controlling the business or individuals with close family ties to the business's managers or controllers. This is a completely new regulation, not previously mentioned, aimed at accurately reflecting the nature of the transaction and resolving practical difficulties.

In parallel, Decree 255/2026/ND-CP also adds a case where the related party relationship does not apply, such as when the creditor or guarantor is a state-owned organization with charter capital, whose function is to buy, sell, and process debt, if it does not directly or indirectly manage, control, contribute capital, or invest in the debtor enterprise or the guaranteed enterprise.

These are the most common scenarios businesses encounter; to fully understand all cases for determining business relationships, as well as cases exempt from filing, businesses should consult a professional advisory firm.

Despite clear regulations, the practical implementation is a bottleneck that causes many businesses to fail when trying to implement them on their own.

The practical difficulties and obstacles that hinder businesses.

While Vietnam's tax policy is transparent, it is also extremely complex technically. Businesses that try to implement it themselves often encounter the following obstacles.

Regulations on controlling interest costs

The total deductible interest expense for corporate income tax purposes must not exceed 30% EBITDA. Notably, according to the transitional provisions of Decree 255/2026/ND-CP, businesses eligible for the carryforward of interest expense deductions under Article 3 of Decree 20/2025/ND-CP will continue to carry forward these deductions for the remaining period, ensuring the continuity of the policy and the rights of taxpayers. Without the support of professional consulting services, accountants often lack the knowledge to optimize capital structure, leading to the exclusion of interest expense from deductible expenses and unnecessarily increasing the corporate income tax burden.

The difference between Accounting Standards and Tax Law

Many transactions are recognized as valid under Vietnamese Accounting Standards (VAS) but are not accepted under regulations on related-party transactions. This lack of consistency causes confusion for businesses when providing explanations. (Consultation needed) related party transaction advisory services This will help correct these discrepancies right from the financial reporting stage.

Challenges in finding comparative data (benchmarking)

Decree 255/2026/ND-CP supplements regulations on database usage priority order When analyzing and comparing related-party transactions:

• Prioritize databases that are publicly available;
• Next is the commercial database;
• Only as a last resort should we use the tax authority's database.

At the same time, the Decree also adds a "national database" as a reliable data source used in declaring and determining transfer pricing, a completely new regulation compared to before. This is a point that businesses need to pay special attention to when choosing data sources to prove transfer pricing, to avoid having their applications rejected due to incorrect priority order. Only professional service providers have sufficient resources to simultaneously utilize publicly available data and international trade data (such as Orbis, Bloomberg, Moody's) in the legally mandated order of priority.

To comply properly, businesses are required to adopt one of the internationally standardized pricing methods.

Analysis of 05 methods for determining transfer pricing.

When preparing the documentation, the compliance service will help businesses choose one of the following methods:

• The Cup (Compare Independent Transactions) price comparison method: Compare product prices directly. This method is the most accurate, but it's difficult to find a perfect match.
• Resale Price Method (RPM): Based on the gross profit margin of the trading business.
• Cost-plus method (CP): This is typically applied to manufacturing and processing businesses.
• Net Profit Margin Comparison Method (NPMR): This is the most common method, based on the profit margin on revenue or costs.
• Profit Sharing Method (PSM): Used for complex transactions, the parties jointly contribute unique intangible assets.

The obligation to declare and determine transfer pricing under Decree 255/2026/ND-CP is now referred to and implemented in accordance with the provisions on the rights and obligations of taxpayers in the 2025 Tax Administration Law, along with specific requirements: 

• Declaring and determining transfer pricing must not reduce the corporate income tax liability payable in Vietnam; 
• It is necessary to demonstrate the performance of the analysis, comparison, and selection of the pricing method; 
• Declare information on related-party relationships and related-party transactions according to the appendices issued with the Decree, and submit them together with the corporate income tax return.

Failure to adhere to these principles can lead to extremely serious financial and legal consequences.

Tax risks arising from a lack of understanding of new regulations.

The risks of not using professional compliance services or of violating regulations are enormous:

• Tax assessment: The tax authorities have the right to determine the profit margin if a company's filing is rejected. This often leads to a significant increase in the amount of tax payable. However, Decree 255/2026/ND-CP adds a very important regulation: the tax authorities are not allowed to use the taxpayer's Country-by-Country Profit Report (CbCR) to adjust or determine the price of related-party transactions; this report can only be managed and used for risk management and information exchange in accordance with international tax agreements that Vietnam has committed to.
• Collection of arrears and penalties for late payment: With the current penalties for late payment, after years of inspection, the total amount of the fine could be equivalent to the original tax amount.
• Reputation risks: Businesses classified as high-risk for tax purposes are subject to more frequent audits and inspections. Maintaining regular compliance services helps businesses maintain their tax credit rating.

Notable positive points: Decree 255/2026/ND-CP supplements regulations on voluntary compliance support programs, according to which tax authorities will develop support programs for businesses with related-party transactions based on risk management, publish industry profit margins for each sector and geographical area to help businesses declare correctly, and are responsible for maintaining the confidentiality of information and data provided by taxpayers participating in the program.

This is why businesses need a professional solution that is fully updated with the latest developments, instead of handling risks themselves.

New points regarding the exemption threshold for preparing Transfer Pricing Documentation.

One of the changes that businesses are most concerned about is Decree 255/2026/ND-CP, which has raised the revenue threshold for exemption from preparing Transfer Pricing Documentation to below VND 500 billion (previously below VND 200 billion), while removing the criterion of "business with simple functions" from the exemption criteria. This adjustment expands the scope of taxpayers with low tax risks who are exempt from preparing the documentation, simplifies the application conditions, and reduces compliance costs. Businesses need to review whether they are still required to prepare the documentation after the revenue threshold has been adjusted.

New features regarding the Country-by-Country Report (CbCR)

For member companies of multinational corporations, Decree 255/2026/ND-CP introduces several important changes regarding the obligation to prepare and submit the Country-by-Country Report (CbCR):

• The global consolidated revenue threshold used to determine the obligation to prepare the CbCR Report is now calculated at the equivalent of 750 million Euros (previously 18,000 billion VND or more), converted using the central exchange rate or the average cross-exchange rate for December published by the State Bank of Vietnam.
• The revenue threshold is now determined based on the revenue of the fiscal year immediately preceding the reporting year, instead of the revenue for the tax period as before.
• The Decree clarifies the cases where the CbCR Report does not need to be submitted in Vietnam (for example, when the report has been automatically exchanged with the Vietnamese tax authorities under an international agreement), as well as the cases where the obligation to submit the report arises in Vietnam.
• The deadline for submitting the CbCR report is no later than 12 months from the end of the fiscal year of the ultimate parent company of the reporting year; the report must be submitted in XML format encoded through the tax management information system.

These are the areas that foreign-invested enterprises and multinational corporations need to particularly review to avoid overlooking obligations or submitting unnecessary reports.

Comprehensive solutions from services complying with Decree 255 on related-party transactions.

We provide a roadmap to help businesses update and fully comply with the new regulations in Decree 255/2026/ND-CP in a safe manner. Detailed service content:

• Prepare a three-level dossier: including the Local File, the Master File, and the Country-by-Country Report of Profits (CbCR), in accordance with the content categories in the appendices issued with Decree 255/2026/ND-CP.
• Reviewing related party relationships: Especially lending and borrowing transactions with individuals who manage or control businesses, this is the most easily overlooked aspect.
• Reviewing key transactions: Assessing the reasonableness of corporate management fees, royalties, and interest expenses according to the new database's priority order.
• Tax Appendix Declaration: Ensure that the figures on the final settlement declaration match the price determination documents, in accordance with the mẫu Appendix I, II, and III issued with Decree 255/2026/NĐ-CP.
• Representing the tax authorities: MAN – Master Accountant Network directly participates in the explanation and dialogue process with the inspection team to defend the data.

In-depth implementation process:

• Model exploration: Value chain analysis and transaction flows.
• Functional, Asset, and Risk Analysis (FAR Analysis): Identify the functions, assets, and risks of related parties, and then conduct an in-depth analysis to determine which party bears more risk in order to allocate profits accordingly.
• Benchmarking: Use the correct database priority order as per the new regulations to filter out the most similar businesses.
• Prepare reports and provide optimal advice: Offer recommendations to help businesses adjust transaction prices to a safe range.

Reference: Related party transaction documentation service.

Service price list in compliance with Decree 255 on related-party transactions.

To ensure transparency, MAN would like to provide your company with the following fee schedule for related-party transaction compliance services:

Note: The price list above is for reference only. The service fee will be finalized after a MAN expert reviews the case file.

Why choose MAN as your partner?

While the market offers many accounting firms, compliance services under Decree 255 on related-party transactions require a combination of up-to-date tax law knowledge, financial skills, and practical experience.

• Specialized expertise: MAN has a specialized team of affiliated traders who focus solely on transfer pricing, and do not offer a wide range of other services.
• Technology and Data: We are committed to using clean, copyrighted data, prioritizing it according to new regulations, and ensuring that applications are not rejected due to data errors.
• Preventive thinking: Our services focus on preventing risks before they occur, and staying up-to-date on any legal changes, rather than just dealing with the consequences.

Conclusion and recommendations

Ignoring or superficially maintaining related-party transaction records, especially failing to update new regulations on related-party relationships, exemption thresholds, and CbCR thresholds, is a risky move for the company's future. Investing in a reputable compliance service that stays up-to-date with the latest regulations is the smartest decision to protect your business achievements from stringent tax audits in Vietnam.

Don't let small mistakes lead to losses of billions of dong. Contact MAN – Master Accountant Network To receive a free risk assessment report!

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
• Google Business Profile: View MAN – Master Accountant Network's Google Business Profile 
• LinkedIn Founder: View expert Le Hoang Tuyen's LinkedIn profile. 

Responsible for production and professional content review by: Mr. Le Hoang Tuyen – Founder & CEO of MAN – Master Accountant Network. He is a CPA Vietnam auditor with over 30 years of in-depth experience in accounting, auditing, taxation, and corporate legal consulting.

Frequently Asked Questions about Services Complying with Decree 255