Transfer Pricing Disclosure Vietnam is an important tax requirement for foreign-invested enterprises (FDI) and multinational companies that conduct transactions with related parties. These businesses must identify their related parties, report relevant transactions, and follow the tax rules that apply to them. In addition, they should keep clear records to support the information in their tax returns. By preparing their disclosures carefully, companies can reduce errors and manage their tax duties more effectively.

Vietnam’s transfer pricing rules changed in 2026. Decree No. 255/2026/ND-CP took effect on July 1, 2026, and applies from the 2026 corporate income tax period onward. Therefore, businesses should check which rules apply to their tax year before preparing their annual tax returns. This is especially important for FDI companies that use the same reporting process each year.

This guide explains the main transfer pricing disclosure requirements in Vietnam. It covers related-party transactions, filing forms, deadlines, exemptions, common mistakes, and practical steps to help businesses prepare for tax reviews.

I. What Is Transfer Pricing Disclosure in Vietnam?

1.1. Meaning of Transfer Pricing Disclosure

Transfer pricing disclosure is the process of reporting information about related parties and their transactions to the tax authorities. For example, a Vietnamese company may buy goods from its foreign parent company or pay service fees to another company in the same group. These transactions may fall within Vietnam’s transfer pricing rules, so the company should check whether it must report them.

The purpose of disclosure is to help tax authorities review transactions between related parties. In particular, they may check whether the prices follow the arm’s length principle. Under this principle, related parties should set prices in line with those that independent businesses would agree to under similar conditions. Therefore, companies should be able to explain how they set their prices and provide suitable supporting records.

1.2. Why Is Transfer Pricing Disclosure Important?

Transfer pricing disclosure helps tax authorities check whether businesses have reported their related-party transactions correctly. It also helps companies find possible tax risks before a tax audit takes place. By reviewing their transactions early, businesses can identify missing information and correct errors before filing their tax returns.

However, submitting a disclosure form does not always meet every transfer pricing requirement. Depending on the company’s circumstances, it may also need to prepare supporting documents. These may include a Local File, a Master File, or a Country-by-Country Report. Therefore, businesses should review both their reporting duties and their documentation requirements.

1.3. Which Businesses May Need to File?

Transfer pricing disclosure may apply to Vietnamese enterprises that have related-party relationships and carry out transactions with those parties. Common examples include FDI companies that buy or sell goods within a multinational group, Vietnamese subsidiaries that pay management fees to overseas affiliates, and businesses that receive loans from related parties. Companies that pay royalties for trademarks, software, or technology should also review their obligations.

However, not every business has the same reporting duties. The requirements may depend on the relationship between the parties, the types of transactions, and any available exemptions. Therefore, companies should review their ownership structure and financial dealings before deciding which forms and documents they need.

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II. Legal Framework for Transfer Pricing Disclosure

2.1. Rules for Tax Periods Before 2026

For tax periods before 2026, businesses should review Decree No. 132/2020/ND-CP, as amended by Decree No. 20/2025/ND-CP, together with other relevant tax rules. These regulations set out key requirements for related-party relationships, transaction disclosure, and transfer pricing documentation. Companies should apply the rules that cover the tax period being reported.

Under the previous framework, businesses generally disclosed related-party transactions through the relevant appendix attached to their annual corporate income tax return. In addition, they had to assess whether they needed to prepare transfer pricing documents. These could include a Local File, a Master File, and a Country-by-Country Report, depending on the applicable conditions.

2.2. Rules for the 2026 Tax Period Onward

For the 2026 corporate income tax period onward, businesses should review Decree No. 255/2026/ND-CP and the relevant tax administration rules. The new decree updates several transfer pricing requirements, including certain documentation exemptions and Country-by-Country Reporting rules. As a result, businesses should check whether their current reporting process still meets the requirements for 2026.

Companies should not automatically reuse forms or guidance from earlier years. Instead, they should confirm the applicable rules before preparing their annual declarations. This is particularly important when a company has changes in ownership, financing arrangements, or related-party transactions.

2.3. What Should Businesses Check?

Before preparing a transfer pricing disclosure, businesses should confirm the following points:

• Which tax period the disclosure covers.
• Which related-party rules apply to that period.
• Which forms and supporting documents are required.
• Whether the company qualifies for any exemptions.
• Whether the information matches the accounting records.

By checking these points early, businesses can reduce the risk of using outdated forms or missing important information. They can also give their accounting teams enough time to collect the required records.

III. Key Transfer Pricing Disclosure Requirements

3.1. Declare Related-Party Relationships

First, businesses should identify their related parties under the rules that apply to the relevant tax period. This review may cover ownership links, management relationships, control, financing arrangements, and other relationships defined by law. Companies should also review changes in ownership or management during the year because these changes may affect their reporting duties.

For each related party, the company should collect key information, including:

• The related party’s legal name.
• Its country or territory of residence.
• Its tax identification number, where applicable.
• The nature of its relationship with the Vietnamese company.
• The types of transactions carried out during the tax period.

In addition, businesses should compare this information with group ownership charts, contracts, and accounting records. This helps ensure that the information is complete and consistent.

3.2. Declare Related-Party Transactions

Next, businesses should identify and report the transactions covered by the applicable disclosure form. These transactions may include purchases, sales, service fees, royalties, loans, interest payments, and guarantees. The company should review each transaction type and confirm that the reported amounts match its accounting records.

For example, if a company reports management fees paid to an overseas affiliate, it should check the amount against the service agreement, invoices, and accounting entries. If the figures do not match, the company should investigate the reason and keep a clear explanation. This process can help prevent errors in the annual tax return and make it easier to answer questions from tax authorities.

3.3. Report Transfer Pricing Methods and Financial Information

Where required, companies must provide information about how they set prices for related-party transactions. This may include the transfer pricing method used, relevant financial figures, and details about the company’s supporting documents. The company should be able to explain why its chosen method is suitable and how it supports the reported results.

For example, a manufacturer may need to explain how it checks the profit earned from sales to related parties. Similarly, a distributor may need to show how its pricing policy reflects the work it performs and the risks it takes. However, the information required may vary by case. Therefore, businesses should follow the official forms and instructions rather than assume that every company must complete every section.

3.4. Check Whether Exemptions Apply

Some businesses may qualify for exemptions from certain transfer pricing documentation requirements. However, the conditions can vary, so companies should not assume that they are exempt simply because they are small or have few related-party transactions.

Before claiming an exemption, businesses should check:

• Whether they meet the relevant revenue or transaction thresholds.
• Whether they satisfy all other conditions under the applicable rules.
• Whether the exemption covers documentation, disclosure, or both.
• Whether they have records to support their claim.

Most importantly, an exemption from preparing transfer pricing documents does not automatically remove every reporting duty. Therefore, businesses should check each requirement separately and keep evidence to support any exemption they claim.

IV. Transfer Pricing Disclosure Forms and Supporting Documents

4.1. Related-Party Transaction Disclosure Form

For tax periods governed by the previous framework, businesses generally reported related-party transactions using the relevant appendix attached to their annual corporate income tax return. For the 2026 tax period onward, businesses should check the forms and instructions that apply under the updated rules.

The disclosure form generally includes information about related parties, their relationships with the company, and the value of relevant transactions. Before filing, companies should check that they have used the correct form and completed all required sections. In addition, they should make sure the reported figures match their accounting records and supporting documents.

4.2. Local File

The Local File describes the Vietnamese company’s business and related-party transactions. Where required, it explains the company’s activities, related-party relationships, pricing methods, financial results, and analysis of similar transactions. It should also show how the company assessed whether its related-party prices followed the arm’s length principle.

Therefore, businesses should ensure that the Local File reflects their actual operations during the relevant tax period. They should also keep evidence to support the figures and explanations in the report. A report that does not match the company’s real business activities may provide weak support during a tax review.

4.3. Master File

The Master File provides information about the wider multinational group. Depending on the applicable rules, it may cover the group’s structure, business activities, global transfer pricing policies, and financial arrangements. This information helps explain how the Vietnamese company fits into the group and how the group manages transactions between related parties.

For this reason, Vietnamese subsidiaries should work with their parent companies to obtain the required information in good time. They should also check that the Master File is consistent with the information in the Local File and annual disclosure. However, the exact requirements depend on the rules and exemptions that apply to the group.

4.4. Country-by-Country Report

A Country-by-Country Report (CbCR) provides information about the allocation of income, taxes, and business activities across countries. Certain multinational groups may need to prepare or submit this report, depending on the applicable revenue threshold and other legal conditions.

However, companies should not rely on the revenue threshold alone. They should also check whether notification, local filing, or other reporting duties apply to their group structure. If the parent company prepares the report overseas, the Vietnamese entity should confirm whether it has any related duties in Vietnam.

V. Filing Deadlines and Common Compliance Mistakes

5.1. When Must Companies Submit the Disclosure?

Related-party transaction disclosure is generally submitted with the annual corporate income tax return under the applicable framework. For companies using a calendar tax year, the usual deadline for annual corporate income tax finalization has generally been the last day of the third month after the end of the tax year. However, businesses should confirm the deadline and filing procedure for their specific tax period.

Companies should also distinguish between filing the disclosure form and preparing supporting transfer pricing documents. Where required, these documents should be ready within the time set by law and retained for presentation to tax authorities. Therefore, businesses should prepare their documents in advance rather than wait until they receive an official request.

5.2. Incorrect Related-Party Information

One common mistake is failing to identify all related parties or reporting the wrong type of relationship. For example, a company may overlook a financing arrangement or fail to update its records after a change in ownership. As a result, the information in the disclosure form may be incomplete or inaccurate.

To avoid this problem, businesses should review their ownership structure, loan agreements, guarantees, and management relationships before filing. They should also confirm that their list of related parties matches the information held by the parent company. This simple check can help reduce errors and improve the quality of the annual disclosure.

5.3. Differences Between Tax Returns and Accounting Records

Another common issue is a mismatch between declared transaction values and the amounts recorded in the accounting system. This may happen because of missing invoices, incorrect account mapping, exchange rate differences, or incomplete reconciliation. If the company does not identify the cause, it may struggle to explain the figures during a tax review.

Therefore, businesses should compare the disclosure form with their general ledger, financial statements, contracts, and payment records before submission. If differences arise, the finance team should investigate them and keep a clear record of the findings. In addition, any required corrections should be made in line with the applicable tax rules.

5.4. Missing Transfer Pricing Documents

Some businesses submit their disclosure forms but do not prepare the supporting documents required by law. However, filing a disclosure form does not automatically satisfy every transfer pricing obligation. Depending on the company’s circumstances, it may also need a Local File, a Master File, or a Country-by-Country Report.

To reduce this risk, companies should assess their documentation duties early. They should also review the relevant exemptions and retain evidence to support any exemption claimed. By doing so, businesses can prepare for a tax review and avoid last-minute work.

5.5. Using Outdated Forms or Rules

Transfer pricing rules can change, and older forms may no longer be suitable for a new tax period. For this reason, companies should review legal updates before preparing their annual tax filings. They should pay particular attention to changes that affect disclosure forms, documentation exemptions, and group reporting duties.

In particular, businesses should distinguish between tax periods before 2026 and the 2026 tax period onward. They should also confirm that their internal procedures reflect the applicable rules. If they use an old form or follow outdated guidance, they may omit important information or complete the declaration incorrectly.

VI. How to Improve Transfer Pricing Disclosure Compliance

6.1. Review Related-Party Transactions Throughout the Year

Businesses should not wait until the annual tax filing period to identify related-party transactions. Instead, they should review these transactions throughout the year and update their related-party lists whenever ownership, management, or financing arrangements change. This approach makes it easier to identify missing information and prepare the annual declaration.

In addition, companies should keep contracts, invoices, payment records, and transaction details in an organized way. They should also assign responsibility for updating the related-party list to a specific team or employee. As a result, the company can reduce the risk of missing transactions when the filing deadline approaches.

6.2. Reconcile Accounting and Tax Information

Next, companies should compare related-party transaction values across contracts, invoices, accounting ledgers, financial statements, and tax returns. They should also check whether the amounts in the disclosure form match the figures used to calculate taxable income. This review can help identify errors before the company submits its return.

If differences arise, the finance team should investigate the cause and document the outcome. Where necessary, the company should correct the figures in line with the applicable rules. By keeping a clear record of these checks, businesses can explain their reported amounts more easily during a tax inspection.

6.3. Coordinate With the Parent Company

FDI companies often depend on their overseas parent companies for group-level information. For example, the parent company may hold the Master File, the group transfer pricing policy, or the Country-by-Country Report. Therefore, the Vietnamese entity should request these records early and agree on a clear timeline for receiving them.

In addition, the company should confirm who is responsible for preparing, reviewing, and submitting each document. Clear communication can reduce delays and help ensure that the information in group reports matches the details reported in Vietnam. This is especially important when the group operates across several countries.

6.4. Keep Records Ready for Tax Reviews

Businesses should store their disclosure forms, contracts, invoices, financial records, and transfer pricing reports in an organized way. They should also retain evidence showing how transaction prices were set and why the chosen method fits their business activities. These records can help support the company’s tax position if the authorities ask for more information.

Moreover, companies should review their records regularly rather than wait until an audit begins. They should check whether documents are complete, easy to find, and consistent with the information in their tax returns. As a result, the company can respond more quickly and reduce disruption to its daily operations.

6.5. Seek Professional Tax Support

Transfer pricing compliance can be difficult, especially for businesses with cross-border transactions, group financing, service fees, or royalty payments. In these cases, professional support can help companies review their related-party relationships, check disclosure forms, and assess documentation duties. An adviser can also help identify potential tax risks before the annual filing date.

In addition, professional support can be useful when a company needs to understand how a new decree affects its reporting duties. By reviewing the facts and the applicable rules, an adviser can help the business prepare accurate records and respond to questions from tax authorities. However, each case should be assessed based on its facts and the relevant legal requirements.

VII. Conclusion

Transfer Pricing Disclosure Vietnam is an important part of tax compliance for FDI companies and multinational groups. Businesses should identify their related parties, report covered transactions accurately, and prepare the supporting documents required by law. In addition, they should review filing deadlines, check exemption conditions, and reconcile disclosure forms with their accounting records before submission.

Since Vietnam’s transfer pricing framework changed for the 2026 tax period onward, companies should apply the rules that match their tax year. By reviewing their obligations early, businesses can reduce reporting errors and improve their readiness for tax reviews. MVA Vietnam provides accounting, tax, and compliance support for businesses operating in Vietnam. Contact our team to discuss your transfer pricing disclosure requirements and improve your tax compliance process.

MVA VIETNAM ACCOUNTING AND AUDITING COMPANY LIMITED