Hiring someone to prepare related-party transaction documents in 2026 is becoming a mandatory solution for FDI enterprises and enterprises with internal transactions, in the context of tax authorities tightening inspections. Decree 132/2020/ND-CP and the Global Minimum Tax Rate (Pillar Two). Even a small error in determining transaction prices, interest expenses, or comparative data can lead to tax arrears, late payment penalties, and placement in a high-risk category for businesses. This article will help you understand who is required to prepare the necessary documentation, the risks of doing it yourself, the cost of hiring a service in 2026, and the criteria for choosing a reputable consulting firm to protect your business from tax audits.
Current status of tax audits and the need for outsourcing the preparation of related-party transaction documentation in 2026.
Entering 2026, tax authorities will not only check the completeness of records but also delve into the economic nature of transactions. Inspection campaigns will focus heavily on businesses with persistent losses but still expanding production, or businesses with profit margins lower than the industry average.
Many businesses currently still handle their own tax declarations; however, due to a lack of proprietary comparative data and insufficient understanding of percentile analysis methods, the risk of rejection is very high. Therefore, the demand for hiring professional consulting firms to prepare related-party transaction declarations is increasing, in order to ensure the documentation has sufficient legal strength before post-audits.
Global Minimum Tax Rate (Pillar Two): A policy that will change the game of transfer pricing.
The year 2026 marks the beginning of the rigorous implementation phase of the Global Minimum Tax Policy (Pillar Two) as stipulated by the OECD. This creates a new layer of complexity on top of the existing regulations of Decree 132/2020/ND-CP.
The complex interplay between Pillar Two and Transfer Pricing
The global minimum tax policy applies a tax rate of 15% to multinational corporations with consolidated revenue of €750 million or more. In Vietnam, the application of additional corporate income tax under the global anti-base erosion regulation makes the valuation of related-party transactions more sensitive than ever.
- Double risk: If a related-party transaction is subject to price adjustments by the Vietnamese tax authorities to inflate profits, the business not only faces retroactive corporate income tax collection under Decree 132 but may also experience changes to its additional tax obligations under Pillar Two in other countries.
- Conflict of Objectives: Businesses tend to want to keep profits low to avoid corporate income tax, but Pillar Two requires an effective tax rate (ETR) no lower than 15%. Balancing these two extremes requires a high level of financial analysis, which can only be achieved by hiring a professional to prepare the Related Party Transaction Documentation.
Strict requirements for international data consistency.
With Pillar Two, data from the Country-Based Report of Earnings (CbCR) will be subject to even closer scrutiny. Any small discrepancies between domestic records and global reports could trigger simultaneous audits from multiple countries. This makes self-reporting a high-risk gamble for corporations.
Reference: Related party transaction advisory services
Why is it necessary to create a Related Party Transaction Profile?
The highest legal basis currently is Decree 132/2020/ND-CP regulating tax management for enterprises with related-party transactions. This is the "guiding principle" that all issues related to related-party transactions must comply with absolutely.
Eligibility and mandatory conditions
According to regulations, businesses that have transactions with related parties (as per Article 5) and are not exempt from documentation requirements (as per Article 19) are required to prepare a set of documents to determine the transfer pricing of related-party transactions.
Key thresholds to note:
- Revenue exceeding VND 50 billion and total value of related-party transactions exceeding VND 30 billion during the tax period.
- Cases involving specific related parties include: Borrowing exceeding 25% of the owner's equity and accounting for over 50% of the total value of medium and long-term debts (Point g, Clause 2, Article 5).
What does a complete application package include?
When a business hires a service provider to prepare the Related Party Transaction Documentation, the provider must complete all three levels of documentation according to the BEPS standard (Action 13):
- Local File: Focuses on specific transactions of entities in Vietnam.
- Global Corporate Profile (Master File): Provides an overview of the business operations and transfer pricing policies of the entire corporation worldwide.
- Country-by-Country Report (CbCR): Only applicable if the group's consolidated total revenue is VND 18,000 billion or more.
Serious risks when businesses do not hire professional transfer transaction documentation services.
Many in-house accountants try to create their own records to save costs, but this often leads to serious financial consequences.
Risks of tax assessment and expense rejection.
This is the biggest risk. If the documentation fails to demonstrate market value (Arm's Length Principle), the tax authorities have the right to use their own database to determine the profit margin. In that case, the business loses its autonomy and often has to accept extremely high back taxes plus late payment interest of 0.031 TP3T/day.
Violation of regulations regarding the limitation of interest expense.
Decree 132/2020/ND-CP stipulates that the total deductible interest expense shall not exceed 30% EBITDA. Incorrect calculations or failure to optimize the transfer of interest expense to subsequent periods will cause businesses to lose a significant amount of tax deductions. (Providers) Related Party Transaction Documentation Service There are usually experts who calculate and optimize this part.
Loss of credibility and image, and being blacklisted by inspectors.
Late or incomplete filing of tax returns signals to the tax authorities that the business should be classified as high-risk. Once on this list, the frequency of inspections and audits will increase, directly impacting business operations.
The outstanding benefits of outsourcing the preparation of Related Party Transaction Documents.
Why do large corporations always prefer to outsource the preparation of related-party transaction documents instead of doing it themselves? The answer lies in the added value that professional services provide.
Accessing a data system for comparing quality
To create a comprehensive financial report, it's necessary to have financial data from similar companies in the market. This includes international data software such as Orbis, Bloomberg, or data from stock exchanges. Companies are unlikely to invest this amount in a single accounting period. This is a key factor in making the report highly persuasive.
Specialization in Functional Analysis (FAR Analysis)
Function, Asset, and Risk Analysis is the "heart" of the documentation. Hiring professionals to prepare a related-party transaction documentation helps businesses gain expertise in presenting information that highlights the risks the business faces, thereby justifying lower profit margins (e.g., market risk, inventory risk, exchange rate risk).
Establishing the optimal independent value range
According to Decree 132, the standard independent transaction value range is from the 35th to the 75th percentile. A good consulting firm will know how to select a comparative sample so that the median falls in the most favorable position for the client's tax obligations while still remaining within a legally safe range.
The value of collaboration in inspection.
When hiring a company to prepare a Related Party Transaction Documentation, businesses receive more than just a file of documents. More importantly, MAN – Master Accountant Network will work with the business to explain and defend the arguments in the documentation before the tax audit team.
Price list for preparing Related Party Transaction Documents in 2026
The cost of hiring a professional to prepare a Related-Party Transaction File in 2026 depends on the size of the business, the number of related-party transactions, the complexity of the file, and the scope of work required. For businesses with only simple loan transactions, the cost is usually lower. Meanwhile, FDI businesses or multinational corporations that need to prepare both Local File, Master File, and comparative data simultaneously will incur higher fees due to the required expertise and processing time. Below is a price list for common service categories:
| Service categories | Scale/Nature | Estimated fee (VND) |
| Declare the Appendix to Related Party Transactions | The company only has simple loan transactions. | 15,000,000 – 30,000,000 |
| Create a Local File | A typical manufacturing/trading business. | 70,000,000 – 130,000,000 |
| Create a complete set of Local Files and Master Files. | Foreign direct investment (FDI) enterprises, multinational corporations. | 150,000,000 – 300,000,000 |
| Benchmarking service (Data search) | Provide a list of comparable companies along with their financial reports. | 40,000,000 – 70,000,000 |
| Consulting services for explaining issues during inspections. | Provide direct support when inspection teams arrive. | Contact for agreement |
Note: The fees listed above are for reference only and may vary depending on the number of related-party transactions, the complexity of the corporate structure, requirements for preparing Local File and Master File, the scope of benchmarking, and whether the business is subject to the Global Minimum Tax Rate (Pillar Two). For businesses with numerous cross-border transactions, intangible asset transactions, internal borrowing, or requiring assistance in explaining matters to tax authorities, actual costs will typically be higher due to the need for in-depth analysis and the use of international comparative data.
Special considerations for businesses in 2026
In 2026, tax authorities will pay particular attention to intangible asset transactions and administrative service fees from parent companies. Especially with the emergence of Pillar Two, hiring a service provider to prepare related-party transaction documentation at this time will help businesses avoid legal discrepancies between countries. Businesses should request clarification from their service provider:
- Real economic benefits: Evidence of providing cross-border services.
- Valuation of intangible assets: Ensuring it aligns with the entity's contribution in Vietnam.
In summary, in the context of the tightened regulations under Decree 132/2020/ND-CP and the impact of the OECD's Global Minimum Tax Rate (Pillar Two), hiring someone to prepare a related-party transaction dossier in 2026 is no longer an expense, but a necessary investment to protect businesses. A properly prepared dossier with reliable comparative data and strong arguments will help businesses minimize the risk of tax assessments, back taxes, late payment penalties, and limit future audit risks.
Conclude
In particular, for FDI enterprises, and those with transactions involving loans, internal sales, service fee payments, or the use of intangible assets from their parent company, proactively hiring someone to prepare a comprehensive related-party transaction dossier will help build a solid legal "shield" from the outset. Instead of waiting until an audit is conducted, businesses should proactively prepare the dossier early to optimize tax obligations while ensuring transparency and safety in long-term business operations.
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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 Hiring a Partner Transaction Profile Provider
Absolutely. This is a reasonable consulting fee to support business operations and tax compliance. In fact, this expense also helps businesses protect interest expenses from being disallowed under Article 16 of Decree 132.
This is where the value of hiring someone to prepare a related-party transaction report becomes clear. Instead of letting the tax authorities determine the profit, MAN's experts will make adjustments to eliminate differentiating factors (such as exchange rate fluctuations). The goal is to demonstrate that even with low profits, the prices applied still comply with the independent transaction principle.
It's possible, but not recommended. A related-party transaction document is a unified whole, from functional analysis to statistical conclusions. If the reasoning and the data don't match in terms of the nature of the risk, the document will reveal significant flaws. When you hire MAN to prepare a complete related-party transaction document, we guarantee consistent logic from start to finish.
Reputable contracts for preparing related-party transaction documentation always include a clause for assisting with audit explanations. MAN will send tax experts to directly participate in meetings with the audit team, answer technical questions about the comparative methodology, and defend the legality of the documentation. This is the most important added value that an individual doing it themselves cannot guarantee.
Extremely risky. According to Decree 132, this is a non-market-priced related-party transaction. Tax authorities often determine interest income based on the average market interest rate (8 - 12%), leading to the retroactive collection of corporate income tax on this fictitious revenue. Having a related-party transaction documentation prepared early will help businesses proactively adjust their borrowing policies or justify the purpose of supporting production and business to minimize losses.How are the costs of hiring someone to prepare the related-party transaction documentation accounted for? Are they deductible when calculating corporate income tax?
What will the consulting firm do if independent benchmarking shows that my company's profit margin is lower than the market average?
Can I hire a service just for benchmarking data, and write the application myself to save money?
In the event of a tax audit, does the company commit to protecting its data to the very end?
Is it really risky for a business to borrow money from its director at an interest rate of 0% to warrant filing a loan application?