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Enterprises transacting with related parties – parent companies, subsidiaries, group companies, controlling lenders, etc. – must declare related-party transaction information and in many cases prepare transfer pricing documentation. This is an area the tax authority focuses on during inspections; errors may lead to tax assessments, disallowed expenses and penalties. ATAX provides a full-service package for related-party transactions, helping enterprises comply fully and defend their pricing policies.

1. Legal basis

• Decree 132/2020/ND-CP (in Vietnamese) on tax administration for enterprises with related-party transactions and its amendments.
• The Law on Tax Administration No. 108/2025/QH15 and Decree 252/2026/ND-CP (the tax authority may assess tax when a taxpayer fails to comply with obligations to declare and determine related-party transaction prices or to provide information as required).
• The CIT Law No. 67/2025/QH15: interest expenses of enterprises with related-party transactions exceeding the prescribed limit are non-deductible.

See also: What are related-party transactions? Key information for enterprises (in Vietnamese).

2. Scope of services

• Identifying related-party relationships and reviewing all related-party transactions during the year.
• Declaring related-party transaction information (Form 01 – Appendix I of Decree 132/2020/ND-CP) submitted with the CIT finalisation dossier.
• Preparing the Local File: functional, asset and risk analysis; selecting the appropriate pricing method; searching and screening independent comparables in databases; determining the arm's length range.
• Supporting the Master File and Country-by-Country Report (CbCR) for groups required to prepare them.
• Calculating the deductible interest expense cap as prescribed.
• Transfer pricing policy advice, review of intra-group agreements, service fees and royalties.
• Support during tax audits: preparing explanations, attending meetings and dialogues.

3. Process

1. Survey the business, group structure and list of related parties.
2. Interview departments to analyse functions, assets and risks.
3. Financial analysis, segmenting related-party and independent transactions.
4. Search comparable data and determine the arm's length range.
5. Prepare Form 01 and the Local File, discuss results and propose adjustments (if any) before finalisation.
6. Deliver the documentation and support its retention and submission upon the tax authority's request.

4. Benefits of ATAX services

• Documentation prepared in the correct form with all required content, ready to submit upon request.
• Early identification of transfer pricing risks and proactive adjustments before assessment.
• Combined with financial statement audit and tax finalisation services, saving time and costs.
• Experts familiar with transfer pricing audit practice in Vietnam.

Contact ATAX for an initial free consultation and a fee proposal for transfer pricing documentation: https://atax.vn.