The time for preparing and submitting related-party transaction dossiers is one of the important milestones that enterprises need to comply with when settling corporate income tax. According to Decree 132/2020/ND-CP and Decree 20/2025/ND-CP, the time for preparing and submitting related-party transaction dossiers must be concurrent with tax settlement dossiers, no later than 90 days from the end of the fiscal year. Late submission or incorrect declaration not only puts enterprises at risk of collection and penalties, but also increases the risk of tax imposition during inspections. Grasping the deadline and preparing complete dossiers is an important step for enterprises to comply with the law and optimize safe tax obligations.
Legal basis for regulating the time for preparing and submitting related party transaction dossiers
To determine the exact time of preparation and submission of documents affiliate transactions, businesses need to base on current legal documents. In particular, Decree 132/2020/ND-CP regulating tax management for businesses with related-party transactions, Decree 20/2025/ND-CP with important adjustments. These documents are the legal foundation for businesses to both comply with the deadline for submitting documents and minimize the risk of being collected and fined.
According to Article 18 of Decree 132/2020/ND-CP, the time for preparing and submitting related party transaction dossiers is stipulated at the same time as the deadline for submitting corporate income tax finalization dossiers, which is 90 days from the end of the fiscal year. This means that enterprises must fully prepare information on related party relationships, related party transactions and price determination dossiers to submit with the tax declaration on time. By Decree 20/2025/ND-CP, this provision continues to be supplemented and adjusted, especially regarding the subjects exempted from declaration and the principles for determining more transparent declaration obligations, helping to reduce the procedural burden for some groups of enterprises.
Strictly adhering to the time limit for preparing and submitting related party transaction dossiers not only helps enterprises avoid the risk of administrative penalties but also minimizes the risk of tax assessment and collection when the tax authority inspects. This is an important requirement for enterprises to ensure compliance with the law while maintaining transparency in financial management and tax strategy.
Update the time of preparation and submission of related party transaction dossiers
To better understand the time to prepare and submit documents for related-party transactions, first of all, businesses need to know exactly when they must prepare documents for related-party transactions according to legal regulations.
Time to create a link profile
According to current regulations, the time for preparing related-party transaction dossiers is directly linked to the time for corporate income tax settlement. Specifically, enterprises with related-party relationships must prepare related-party transaction dossiers immediately upon performing tax settlement for the fiscal year. Preparing dossiers at this time is not only a mandatory requirement under Decree 132/2020/ND-CP, but also an important step to ensure transparency in determining costs, revenue and tax obligations.
Time for submitting documents for related party transactions
According to Decree 132/2020/ND-CP, the time for submitting the related party transaction dossier is linked to the deadline for submitting the annual corporate income tax (CIT) finalization dossier. Specifically, enterprises must submit the related party transaction dossier at the same time as the CIT finalization declaration, ensuring full and accurate submission to the tax authority. The final deadline is stipulated to be no later than 90 days from the end of the fiscal year.
This means that as soon as the enterprise completes the tax settlement dossier, the related party transaction dossier must also be prepared in parallel and submitted at the same time. If the enterprise submits late, does not submit or does not declare on time, it will be subject to administrative penalties and may also incur greater risks such as tax assessment or tax collection during the inspection and examination process.
Complying with the deadline for submitting related party transaction dossiers not only helps businesses meet legal requirements, but also demonstrates transparency in tax administration, contributing to minimizing risks when tax authorities conduct inspections.
For example: For the fiscal year ending December 31, 2024, the deadline for submitting the related party transaction declaration is March 30, 2025.
The importance of timely completion and submission of related party transaction documents
To better understand the meaning and practical value, below are some highlights on the importance of completing and submitting related party transaction dossiers on time:
- Mandatory legal obligations: The time for preparing and submitting related party transaction dossiers is clearly stipulated in Decree 132/2020/ND-CP and Decree 20/2025/ND-CP, and enterprises are required to comply.
- Avoid penalty risks: Violations of payment deadlines will be subject to penalties as prescribed by law, including fines, arrears and late payment interest.
- Minimize the risk of tax assessment: Paying on time helps businesses reduce the risk of tax assessment or collection measures being applied by tax authorities during inspections.
- Ensuring financial transparency: Compliance with regulations helps demonstrate transparency in cost management, revenue and tax obligations.
- Optimizing long-term tax strategy: Compliance from the beginning lays the foundation for businesses to effectively manage taxes, minimize disputes and support sustainable development.
Because the time for preparing and submitting documents for related-party transactions is crucial in complying with the law and limiting tax risks, enterprises not only need to ensure the deadline but also need to fully prepare the accompanying documents. This is the basis for proving the reasonableness and transparency of related-party transactions and is an important document when the tax authority conducts inspections and checks.
Documents to be attached when submitting related party transaction dossier
To help businesses easily distinguish between cases that must declare and cases that are exempted from declaring transfer pricing documents, to carefully prepare documents and submit them within the prescribed time limit.
See details: Cases of declaration and exemption from declaration of valuation dossier
Consequences of late submission of documents for preparing and submitting related-party transaction documents or failure to submit
According to Decree 125/2020/ND-CP, the penalties for violations regarding the time of preparation and submission of related-party transaction dossiers are as follows.
“A fine from VND 8,000,000 to VND 15,000,000 shall be imposed for one of the following acts:
- Submitting tax declaration documents 61 to 90 days past the prescribed deadline;
- Submitting tax declaration documents 91 days or more after the prescribed deadline but no tax payable arises;
- Not submitting tax return but no tax payable;
- Failure to submit appendices as prescribed in tax management regulations for enterprises with related transactions attached to corporate income tax settlement dossiers.
A fine of between VND 15,000,000 and VND 25,000,000 shall be imposed for the act of submitting a dossier more than 90 days after the deadline for submitting a tax declaration dossier, with tax payable arising and the taxpayer having paid the full amount of tax and late payment to the state budget before the tax authority announces the decision to conduct a tax audit or inspection or before the tax authority makes a record of the act of late submission of a tax declaration dossier as prescribed.”
In addition, if an enterprise fails to submit a dossier of related-party transactions or intentionally fails to fulfill its obligation to declare within the time limit for preparing and submitting a dossier of related-party transactions, the penalty will be very severe. According to the law on tax administration, an enterprise may be fined a percentage of the tax under-declared, usually 20% of the tax under-declared due to the act of not declaring or declaring incorrectly, leading to a lack of tax obligations. In addition, if the tax authority determines that there are signs of tax evasion, the penalty may be increased to 1-3 times the amount of tax evaded, along with additional collection and late payment fees.
This shows that timely compliance with the preparation and submission of related party transaction declarations is very important for businesses to avoid unnecessary penalties and minimize risks during tax inspections.
Conclude
It can be seen that timely compliance with the preparation and submission of related party transaction documents not only helps businesses avoid fines ranging from tens of millions of VND to the risk of being taxed, but also affirms transparency in financial management. To minimize risks and ensure safety during inspections, businesses should proactively prepare documents early, carefully review data and promptly update new regulations. If you want to have an effective compliance roadmap and a sustainable tax optimization strategy.
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