Tax policies are increasingly tightened, consulting on updating new regulations on related party transactions (FDI) has become an essential need for most businesses. Changes from Decree 132/2020/ND-CP and new guiding documents not only directly impact the obligation to declare and prepare documents but also affect the financial strategy and tax risks of businesses. MAN - Master Accountant Network with a team of experienced experts in the field, businesses not only promptly grasp new regulations but also receive support in building optimal solutions, ensuring compliance with the law and improving transparency in business operations.
Introduce
Tax policies related to related party transactions in Vietnam are highly complex and are regularly adjusted to approach international standards on affiliate transactions and anti-transfer pricing. This creates great pressure for the accounting and finance department of enterprises, especially foreign-invested enterprises or multi-industry enterprises. Consulting services to update new regulations on GDLK not only help enterprises understand correctly and apply the regulations, but also support the development of transfer pricing strategies, manage loan interest expenses, and prepare transparent GDLK documents, meeting the requirements of tax authorities. This is the "shield" that helps enterprises minimize tax risks, while optimizing legitimate benefits in production and business activities.
Updating new regulations on related party transactions plays a key role in ensuring compliance with the law and avoiding the risk of tax authorities determining taxable income or excluding unreasonable expenses. Continuous changes from Decree 132/2020/ND-CP and additional instructions in 2025 require businesses to closely monitor, because even a delay or misunderstanding of regulations can lead to errors in declaring and documenting related party transactions.
Overview of new regulations on Related Transactions in 2025
Consulting on updating new regulations on GDLK has become an essential need for businesses in the context of management agencies increasingly tightening tax administration activities. The year 2025 marks many important adjustments related to the legal basis, scope of application and declaration obligations of businesses.
Legal basis
The legal framework is still mainly based on Decree 132/2020/ND-CP of the Government, combined with the guiding Circular of the Ministry of Finance. However, in 2025, the new GDLK regulations will be updated in a more transparent direction, in line with international practices on transfer pricing management, ensuring that Vietnam fulfills its commitment to combat tax base erosion.
Main changes compared to before
Compared to the previous period, some of the contents updated with new GDLK regulations are outstanding as follows:
- Additional details about limit on interest expenses when calculating corporate income tax, especially for businesses with many loans from related parties.
- Expanding the scope identify the affiliate and related party transaction conditions, to cover more complex situations.
- Tighten country-by-country reporting (CbCR) requirements for multinational corporations with subsidiaries in Vietnam.
- Strengthening the obligation to provide information in GDLK profile to make it easier for tax authorities to compare and analyze transfer pricing risks.
Impact on obligations to declare, prepare GDLK records and submit tax reports.
The new GDLK regulations update requires businesses to comprehensively review their related party transactions to ensure accuracy in declaring Forms 01, 02, 03 as prescribed. At the same time, the preparation and maintenance of GDLK records are increasingly detailed, requiring coordination between many departments in the business. If the regulations are not strictly followed, businesses are at risk of having their costs excluded, having their taxes collected, or being fined for administrative violations. Therefore, updating the new GDLK regulations not only helps businesses comply promptly, but also provides solutions to optimize costs and minimize legal risks in the long term.
See also: Instructions for declaration on the declaration system and appendix according to Decree 132
To help businesses easily visualize the important changes, below is a comparison table between the GDLK regulations before and after the update of the new GDLK regulations. This table not only shows the specific differences but also emphasizes why the update of the new GDLK regulations is more necessary than ever:
Board: Comparison between related party transaction regulations before and after updating new regulations
| Regulation content | Before 2025 | Updated 2025 | Impact on business |
| Interest expense | 30% EBITDA deduction limit, with carryforward mechanism Decree 68/2020/ND-CP | More detailed regulations, additional calculation method for loans from related parties | Enterprises must strictly control their loan structure and need to update new regulations on foreign exchange to avoid being excluded from expenses. |
| Identify the affiliate | Based on ownership ratio, control rights, large loan relationships | Expanded scope, adding new situations such as indirect control agreements | Enterprises need to review the entire system of subsidiaries and affiliates. |
| GDLK Profile | Requires 3 levels of establishment (Local, Global, CbCR) for businesses in the following categories: | Add more detailed requirements for comparative analysis and supporting data | Businesses must prepare more transparent documents, increasing pressure on human resources |
| Country-by-Country Reporting (CbCR) | Only applicable to multinational corporations with a turnover of EUR 750 million or more | More detailed reporting requirements, wider scope of application for subsidiaries in Vietnam | Small and medium enterprises are less affected, but FDI enterprises need to pay special attention. |
| Sanctions | Penalties for violations of declaration and late submission of documents | Increased penalties, additional stricter tax assessment measures | Businesses are at great risk if they do not comply promptly. |
From the comparison table, it can be seen that the changes in the regulations on related-party transactions do not stop at adding calculation techniques but also expand the scope of management and strengthen sanctions. This means that businesses need to be more proactive and transparent in tax administration. However, in reality, understanding and correctly applying these regulations is not simple. This is a big challenge that makes it difficult for many businesses to declare, prepare documents and control risks.
Challenges for businesses when applying new regulations on GDLK
The implementation of new GDLK regulations in the management of related party transactions in 2025 brings many new pressures to businesses, especially in the process of filing and tax administration. Some typical challenges include:
- Identifying related parties is increasingly complex: Previously, the scope of related parties was mainly based on ownership ratio or loan relationship. However, with the update of new GDLK regulations, enterprises must also take into account cases of indirect association, control contracts or management agreements. This can easily cause accounting and finance to miss or misidentify, leading to risks when declaring.
- Significant increase in the volume of GDLK documents: The requirements under the new GDLK regulations require businesses to prepare more detailed comparative analysis documents, with full supporting data from third parties. This puts great pressure on the accounting department, especially for companies that do not have a modern financial management data system.
- Risk of expense exclusion, especially interest expense: With stricter regulations on controlling interest expense, businesses are easily excluded if they do not calculate EBITDA correctly or cannot prove the purpose of the loan. This case not only increases corporate income tax expense but also directly affects cash flow.
- Higher risk of being inspected and taxed: Enterprises that submit documents late, with missing or incorrect information are very likely to be subject to in-depth inspection. In that case, not only will they be administratively fined, but they will also be at risk of having to pay large tax arrears, affecting their reputation and business capital.
- Lack of specialized personnel to handle complex regulations: Many SMEs or FDI enterprises in Vietnam do not have a team with in-depth knowledge of transfer pricing and related-party transactions. Self-implementation is prone to errors, while the cost of overcoming risks is often much higher than hiring a consultant from the beginning.
Understanding the above challenges, with a team of experienced and knowledgeable people in the field, MAN - Master Accountant Network provides in-depth consulting services on updating new regulations on GDLK to help businesses understand correctly and do it correctly, limiting legal risks.
Consulting on updating new regulations on GDLK helps businesses:
- Explain clearly about the new GDLK regulation update.
- Support businesses in declaring, establishing and maintaining correct GDLK records, avoiding errors that lead to cost exclusion or penalties.
- Analyze transaction structure, interest expense and related items to find solutions to minimize legal tax burden.
- Reduce inspection and control risks
- Not only handling immediate tax obligations, consulting also helps businesses design sustainable financial and tax management strategies, in line with international standards.
MAN Service Delivery Process – Master Accountant Network
MAN – Master Accountant Network builds a consulting service process to update new regulations on GDLK following a strict sequence to ensure quality:
Step 1 – Receive requests: Record customer information and requests via phone, email, and website.
Step 2 – Survey consultation: Learn about the business, analyze the situation to come up with a suitable service plan.
Step 3 – Signing the contract: After agreement, proceed to sign the service contract between the two parties.
Step 4 – Service implementation: MAN – Master Accountant Network assigns an accountant in charge of receiving documents and performing the committed accounting work.
Step 5 – Acceptance report: Periodically report work progress and results for customer review and feedback.
Step 6 – Customer care: Always ready to support and advise customers when problems arise.
Step 7 – Evaluate improvements: Listen to customer feedback to continuously improve service quality.
The service provision process at MAN – Master Accountant Network complies with the principles in Articles 13 and 18 of the 2015 Accounting Law, including organizing accounting work, storing documents and ensuring legal responsibility.
Conclude
Tax policies and regulations on related-party transactions are constantly changing, so it is vital for businesses to proactively update and properly apply regulations to minimize legal risks and optimize financial strategies. However, not all businesses have enough resources and expertise to handle these complex requirements.
That is why the consulting service to update new regulations on GDLK becomes a reliable companion solution. With legal understanding, practical experience and commitment to transparency, MAN – Master Accountant Network not only helps businesses comply with standards but also creates a sustainable financial foundation.
If your business is still wondering about the changes and updates on related-party transactions, don't wait until risks arise to find a solution. Be proactive in choosing consulting services to update new GDLK regulations to ensure compliance with the law, optimize legal costs and build a solid financial foundation for the future.i.
Contact information: MAN – Master Accountant Network
- Address: No. 19A, Street 43, Binh Thuan Ward, District 7, Ho Chi Minh City.
- Mobile/zalo:+84 (0) 903 963 163 or +84 (0) 903 428 622
- E-mail: man@man.net.vn
Editorial Board: MAN – Master Accountant Network