Professional and reputable related-party transaction advisory firm in Ho Chi Minh City.

In the context of a globalized economy in 2026, foreign direct investment (FDI) enterprises and multinational corporations in Ho Chi Minh City are facing an unprecedented wave of tax audits. The tax authorities' extensive application of artificial intelligence (AI) and Big Data to review cross-border profit data has put many businesses on alert. If transfer pricing documentation is not meticulously prepared, the risk of tax arrears, late payment penalties, and the exclusion of interest expense under the 30% EBITDA limit is unavoidable.

In particular, the implementation of the Global Minimum Tax Policy (Pillar Two) in Vietnam has completely changed the game. To protect legitimate interests and maintain reputation in the market, partnering with a professional related-party transaction advisory firm is no longer an option, but a mandatory requirement for FDI corporations and businesses.

Key changes to related-party transactions in 2026

Entering 2026, the legal framework for tax management of related-party transactions in Vietnam has made significant progress towards aligning with OECD standards and the Base Erosion Prevention Scheme (BEPS).

The core basis of Decree 132/2020/ND-CP

Decree 132/2020/ND-CP These still serve as guidelines for determining transfer pricing. Accordingly, businesses need to pay attention to the following key thresholds:

• Revenue threshold: Businesses must have revenue exceeding 50 billion VND during the tax period.
• Transaction value threshold: The total value of related-party transactions exceeds VND 30 billion.
• Interest expense limitation (Article 16): This regulation stipulates that the total deductible interest expense must not exceed 30% of EBITDA. This is a frequently scrutinized point by the Ho Chi Minh City tax authorities during audits of businesses with large internal loans from their parent companies.

To better understand the operational procedures and preparation steps, businesses can refer to the details at related party transaction advisory services To have a precise implementation roadmap.

Global Minimum Tax (GMT): A Challenging New Variable

From 2024 and with strong enforcement in 2026, Vietnam will apply an additional corporate income tax under global anti-base erosion regulations. Multinational corporations with consolidated revenue of €750 million or more will face a minimum tax rate of 15%. The intervention of a related-party transaction advisory firm is now crucial to balance tax obligations in Vietnam with the additional global obligations.

• Risk crossover: A small error in determining transfer pricing resulting in lower-than-actual profits in Vietnam could trigger additional taxes in the parent company's country or even in Vietnam itself.
• Double impact: Businesses must both comply with the three-tiered documentation requirements under Decree 132/2020/ND-CP and calculate the actual tax rate (ETR) to ensure compliance with the GMT rule. This requires the analytical capabilities of a related-party transaction advisory firm with an international perspective (such as the Big4 or MAN – Master Accountant Network) and a deep understanding of complex tax calculation techniques.

Risks of conducting these transactions independently without going through a professional affiliate trading advisor.

Many businesses in Ho Chi Minh City still try to create their own related-party transaction records to save costs, but this often leads to serious errors:

Errors in identifying related parties.

Related parties are not limited to ownership percentages. Many businesses overlook related parties through management, control, or exclusive business relationships that account for a significant proportion of the company's assets. A professional related-party transaction advisory firm will conduct a thorough review of the group's structure, both broadly and deeply, to ensure no related parties are overlooked, thus avoiding the rejection of the entire tax return due to missing declared entities.

Choose a method for comparing price discrepancies.

Choosing the wrong methodology (such as using the independent transaction price comparison method when there is a lack of matching data) will undermine the logic of the documentation. In the context of global minimum tax rates, choosing the wrong methodology not only affects corporate income tax in Vietnam but also distorts the ETR (Equity Value Added Tax) figures used for reporting to the parent company. Therefore, businesses need support from a related-party transaction compliance consultant to assess the most appropriate methodology for the economic nature of the transaction.

The data used for comparison is unreliable (Benchmarking).

Businesses often lack access to databases such as Orbis, Bloomberg, or TP Tool. Using unofficial data is immediately rejected by tax authorities, leading to tax assessments based on internal tax data, which are often much harsher than actual market conditions.

In-depth analysis of 5 methods for determining the price of related-party transactions.

To ensure the highest level of compliance, every reputable related-party transaction advisory firm must master and accurately apply one of the following methods as stipulated by Vietnamese law:

• The Contra-Independent Transaction Price Comparison (CUP) method: Compares the price of a related-party transaction with the price of a transaction between independent parties. This method requires absolute similarity in products and contract conditions.
• Resale Price Method (RPM): Based on the resale price of goods to an independent party minus a suitable gross profit margin. Typically applied to businesses engaged in pure trading and distribution.
• Cost-plus pricing (CPM) method: Based on the cost of goods sold plus an appropriate gross profit margin. Often implemented by related-party transaction advisory firms for businesses engaged in contract manufacturing and order-based production.
• The Net Profit Margin (NPRI) comparison method: Compares the net profit margin on revenue, expenses, or assets. This is currently the most common method in Vietnam due to its high flexibility in finding comparative data.
• Profit Split Method: Sharing the total profit of affiliated parties based on their contributions in terms of function, assets, and risk (FAR Analysis). This method is extremely complex and is usually only applied to highly integrated, specialized transactions.

Why do businesses need a professional related-party transaction advisory firm?

In an increasingly digitized tax administration environment and with constantly updated policies (such as the Global Minimum Tax – Pillar Two), the role of a related-party transaction advisory firm is extremely important. Seeking expert advice on this matter is crucial. Related party transaction compliance consulting This will help businesses mitigate potential risks:

• Instant policy updates: Regulations on GMT, BEPS 2.0, and Decree 132/2020/ND-CP., Decree 20/2025/ND-CP Amendments and additions to Decree 132. Specialized consulting units will help businesses adjust their strategies in a timely manner, avoiding the application of outdated regulations that could lead to administrative violations.
• Multinational specialization: Our team of experts is not only proficient in Vietnamese law but also knowledgeable about international tax agreements, helping to optimize tax obligations globally rather than focusing on a single country. Support from our related-party transaction advisory firm helps harmonize the group's interests across multiple jurisdictions.
• Protecting your interests during audits: Experience in explaining matters to tax audit teams in Ho Chi Minh City helps consulting firms know how to defend their professional viewpoints in the files, explain statistical discrepancies, and minimize the amount of back taxes, late payment penalties, or even tax assessments.

Standard procedures at reputable related-party transaction advisory firms.

A professional and reputable related-party transaction advisory firm will implement the service following a rigorous 5-step process, ensuring the highest level of transparency and reliability for your company's documentation:

• Step 1 – Health Review: Identify risk “red zones” and assess the impact of the Global Minimum Tax on the current structure. This is a crucial step to help businesses proactively adjust their strategies.
• Step 2 – Functional, Asset, and Risk Analysis (FAR Analysis): Establish an accurate functional profile to protect a reasonable level of profit retained in Vietnam, avoiding being considered as illegally transferring profits abroad.
• Step 3 – Benchmarking: Use copyrighted international trade data to find the benchmark market profit margin. A quality affiliate trading advisory firm will provide reliable benchmark reports for tax authorities.
• Step 4 – Prepare the 3-level documentation (Local File, Master File, and CbCR): Complete the reporting system to comply with Decree 132 and international reporting requirements. Preparing a complete 3-level documentation set is the clearest evidence of a company's professionalism.
• Step 5 – Support in explaining: We accompany businesses throughout the entire process of working with the Tax authorities in Ho Chi Minh City, ensuring consistency in all messages and information provided, avoiding unfortunate errors due to language barriers or misunderstandings.

Criteria for selecting a related-party transaction advisory firm in Ho Chi Minh City.

Use the following criteria to choose the right partner for 2026:

• Professional License: Must be licensed by the Ministry of Finance to provide tax or auditing services. This is a prerequisite for the application to be legally valid. The team of auditors must hold CPA or ACCA certifications.
• International capabilities: In-depth understanding and ability to advise on OECD's Global Minimum Tax (Pillar Two), the Base Erosion Control Mechanism, and cross-border tax issues, BEPS 2.0.
• Database system: It is essential to own the licenses for reputable international comparative data systems such as Orbis and Bloomberg. Consulting firms dealing with related-party transactions that lack standardized data will be unable to protect businesses during audits, and their records are easily dismissed.
• Possesses in-depth and broad knowledge of the field of Related Party Transactions.

Conclusion: Compliance is the foundation of sustainable development.

In 2026, the line between tax optimization and wrongdoing is thinner than ever. The introduction of the Global Minimum Tax has ended the era of complex tax structures designed to evade obligations. Now, transparency and compliance are core values for business survival.

Collaborating with a professional related-party transaction advisory firm is not just about "dealing" with inspection teams, but about building a safe, sustainable, and professional financial strategy in the eyes of international investors. Tax policies are constantly changing, and seeking the services of a professional related-party transaction advisory firm is the smartest investment decision for the future of your business.

Contact Contact MAN – Master Accountant Network for timely advice and support!

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.

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