FDI and Transfer Pricing Tax Advisory in Vietnam
Related-party documentation, benchmarking and defence for foreign-invested enterprises.
Transfer pricing advisory for foreign-invested enterprises covers the full compliance cycle under Decree 132/2020/ND-CP: identifying related parties, preparing the related-party disclosure forms filed with the annual corporate income tax return, building the Local file and Master file, benchmarking each controlled transaction, and defending the analysis when the tax authority reviews it.
Vietnam’s transfer pricing rules apply far more broadly than most foreign parent companies expect. A relationship arises not only from shareholding but also from guarantees, loans, shared management and dependence on a single supplier or customer, so a company with no foreign shareholder at all can still fall within scope. Once a company is in scope, the annual disclosure forms must be filed with the corporate income tax finalisation, and contemporaneous documentation must exist before that filing date rather than being assembled after an inspection notice arrives. Where documentation is missing or the pricing cannot be supported, the tax authority may set the price itself using its own database, and the resulting adjustment carries both the tax and the late-payment interest running from the original due date. The separate interest limitation rule caps deductible net interest expense at thirty per cent of EBITDA, which frequently affects subsidiaries funded by intercompany loans from the parent.
Scope of service
What the service includes
Related-party mapping
Identify every relationship and controlled transaction within the group.
Disclosure forms
Prepare the appendices filed with the annual corporate income tax return.
Local file
Functional analysis, method selection and benchmarking of each transaction.
Master file and CbCR
Coordinate group-level documentation and country-by-country reporting.
Interest limitation review
Model the thirty per cent EBITDA cap on deductible net interest expense.
Inspection defence
Prepare explanations and supporting evidence during a tax audit.
Method
How a transfer pricing engagement runs
- Scoping. Confirm which entities and transactions are related-party transactions under Decree 132/2020/ND-CP and whether any exemption applies.
- Functional analysis. Document the functions performed, assets used and risks borne by the Vietnamese entity relative to its counterparties.
- Method selection. Choose the most appropriate method and justify why the alternatives were rejected.
- Benchmarking. Build a comparable set from a recognised database and derive the arm’s length range.
- Documentation. Issue the Local file in Vietnamese and English, and align it with the Master file.
- Filing and defence. File the disclosure forms with the finalisation return and support the company through any subsequent review.
Exemptions
Who is exempt from preparing the documentation?
| Condition | Threshold | Effect |
|---|---|---|
| Small taxpayer | Revenue below VND 50 billion and controlled transactions below VND 30 billion in the year | Exempt from the Local file and Master file; disclosure forms still required |
| Advance Pricing Agreement | Signed APA covering the transactions | Documentation follows the APA terms |
| Simple functions | Revenue below VND 200 billion with declared profit ratios at or above the prescribed levels | Exempt from documentation for the qualifying activity |
| Domestic transactions | Both parties subject to the same corporate income tax rate with no incentive applied | Exempt where the conditions in the decree are met |
Exemption from documentation is not exemption from the arm’s length principle. A company relying on an exemption should still hold evidence supporting its pricing, because the tax authority may test the transaction during an inspection regardless of whether a Local file was required.
Fees
How is the fee determined?
Á Châu quotes by scope after reviewing the number of controlled transactions, the number of counterparty jurisdictions and whether benchmarking studies must be built from scratch or refreshed. The quotation is issued in writing before the engagement starts and distinguishes the annual documentation cycle from ad hoc inspection support.
Related services
Services often combined with this one
- Tax consulting service — corporate income tax, value-added tax and personal income tax advice.
- Tax risk management advisory — internal controls and pre-inspection review.
- Full-service accounting — statutory bookkeeping for the Vietnamese entity.
- Corporate tax finalisation service — the annual return the disclosure forms attach to.
Legal basis
Legal basis
- Decree 132/2020/ND-CP — tax administration for enterprises with related-party transactions.
- Decree 20/2025/ND-CP — amendments to the related-party definition and interest limitation rule.
- Law on Tax Administration No. 38/2019/QH14 — filing obligations and assessment period.
- Decree 126/2020/ND-CP — guidance on the Law on Tax Administration.
- Circular 80/2021/TT-BTC — tax administration forms and procedures.
- Law on Corporate Income Tax and its guiding circulars — deductibility of expenses.
This page is general information current at the date of update. Please check the legislation in force or contact Á Châu before applying it to a specific case.
FAQ
Frequently asked questions
Updated 4 September 2026.
Review your transfer pricing position
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