The Significant Benefits of Hiring a Related-Party Transaction Advisor<\/figcaption><\/figure>\nThe decision to hire a related-party transaction consultant provides strategic value that the internal accounting department would find difficult to achieve on its own:<\/span><\/p>\n<\/span>Optimizing Tax Obligations Within the Legal Framework<\/b><\/span><\/h3>\nHiring a related-party transaction consultant is not only for documentation purposes but also helps businesses review their operational structure. For example, according to Clause 3 of Article 16 of Decree 255\/2026\/ND-CP, the total deductible interest expense\u2014after deducting interest on deposits and interest on loans incurred during the period by the taxpayer\u2014is deductible when determining taxable income for corporate income tax purposes, provided it does not exceed 30% of the total net profit from business operations during the period plus interest expense after deducting interest on deposits and interest on loans incurred during the period, plus the taxpayer\u2019s depreciation expenses incurred during the period.<\/span><\/p>\nTaxpayers shall report the interest expense ratio for the period in accordance with Appendix I issued pursuant to the Decree (point d, paragraph 3, Article 16).<\/p>\n
Important Note: <\/strong>Taxpayers who are exempt from filing a tax return and from preparing a transfer pricing documentation file must still determine the total deductible interest expense in accordance with Article 16, Paragraph 3. When hiring a transfer pricing consultant, the consulting firm will help you optimize your capital structure to avoid the unintended disallowance of this expense.<\/p>\n<\/span>Ensuring absolute compliance.\u00a0<\/b><\/span><\/h3>\nRelated-party transaction documentation is very complex and consists of three levels. When hiring a related-party transaction advisor, the expert ensures consistency in:<\/span><\/p>\n\n- Country File (Local File): Detailed analysis of transactions in Vietnam.<\/span><\/li>\n
- Global Group Master File: Information on the group-wide transfer pricing strategy.<\/span><\/li>\n
- Country-by-Country Reporting (CbCR): Applies when the ultimate parent company has consolidated global revenue of 750 million euros or more in the fiscal year immediately preceding the reporting year (Article 19, Annex IV). The exchange rate is determined based on the central exchange rate or the average cross-rate for December of the year immediately preceding the reporting year, as published by the State Bank of Vietnam. The deadline for submission is no later than 12 months from the end of the ultimate parent company\u2019s fiscal year.<\/span><\/li>\n<\/ul>\n
Documentation establishing the price of related-party transactions must be prepared prior to the filing of the annual corporate income tax return and must be retained and presented upon request by the tax authorities.<\/p>\n
<\/span>Access to Accurate Benchmarking Data<\/b><\/span><\/h3>\nParagraph 3 of Article 17 of Decree No. 255\/2026\/ND-CP stipulates that databases shall be used in the following order of priority:<\/p>\n