Transfer Pricing Documentation Requirements Vietnam are important for foreign-invested enterprises (FDI) and multinational companies that conduct transactions with related parties. These businesses must report their related-party transactions and prepare the required documents to show how they set their prices. In addition, they must check whether their transactions follow the arm’s length principle and meet Vietnam’s tax rules. By preparing the right documents, companies can reduce tax risks and respond more effectively to tax inspections.

I. What Are Transfer Pricing Documentation Requirements in Vietnam?

1.1. Meaning of Transfer Pricing Documentation

Transfer pricing documentation is a set of records that explains a company’s transactions with related parties and how it determines the prices of those transactions. These records help tax authorities assess whether the prices reflect the company’s business activities and follow the arm’s length principle. For example, a Vietnamese subsidiary that buys goods from its foreign parent company should be able to explain how the purchase prices were set.

In Vietnam, companies must assess their related-party transactions and prepare the documents required by the applicable rules. Depending on their circumstances, these documents may include a Local File, a Master File, and a Country-by-Country Report. In addition, businesses should keep contracts, invoices, financial records, and other evidence that supports their pricing decisions.

1.2. Why Is Transfer Pricing Documentation Important?

Transfer pricing documentation helps businesses explain how they set prices for transactions within their corporate group. It also allows tax authorities to assess whether the company’s reported income and expenses are consistent with the applicable rules. Without suitable documents, a company may find it harder to explain its pricing policy during a tax inspection.

Moreover, preparing these documents can help businesses identify problems before they become larger tax issues. For example, a company may find that its management fees lack supporting evidence or that its profit level does not match its business functions. By reviewing these issues early, the company can improve its records and reduce the risk of tax disputes.

1.3. Which Companies Need to Review These Requirements?

Transfer pricing documentation requirements are relevant to Vietnamese businesses 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 or technical service fees to overseas affiliates.
• Companies that receive loans or guarantees from related parties.
• Manufacturers that pay royalties for trademarks, software, or technology.
• Businesses that provide services to other companies in the same group.

However, the exact documentation duties depend on the applicable rules and any available exemptions. Therefore, companies should review their related-party relationships, transaction values, revenue, and business activities before deciding which documents they must prepare.

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II. Legal Framework for Transfer Pricing Documentation in Vietnam

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 requirements for related-party disclosures, transfer pricing methods, and supporting documents. Companies should apply the rules that govern the tax period under review rather than use the latest rules automatically.

Under the previous framework, businesses generally reported related-party information through the relevant appendix attached to their annual CIT finalization return. They also had to assess whether they needed to prepare a Local File, a Master File, or a Country-by-Country Report. However, certain businesses could qualify for exemptions if they met the conditions set out in the regulations.

2.2. Rules for the 2026 Tax Period Onward

For the 2026 CIT period onward, businesses should follow Decree No. 255/2026/ND-CP and the relevant tax administration rules. The new decree retains the main transfer pricing framework while updating several requirements. These changes include documentation exemptions, rules for Country-by-Country Reporting, and the priority given to different sources of data used in transfer pricing analysis.

As a result, businesses should review their existing procedures before preparing their 2026 documents. They should also check whether their current forms and supporting records meet the new requirements. This is especially important for FDI companies that have used the same documentation process for several years without reviewing changes in the law.

2.3. Key Compliance Duties

Under the applicable framework, companies should review the following duties:

• Identify related parties and report covered transactions.
• Prepare the required transfer pricing documentation.
• Conduct a comparability analysis and select a suitable pricing method.
• Keep supporting records and evidence for their pricing decisions.
• Prepare and retain documents before the annual CIT return filing deadline.
• Provide the required documents when requested by tax authorities.

In addition, businesses should check whether any exemptions apply to their circumstances. An exemption from preparing certain documents does not always mean that the company is exempt from all related-party reporting duties.

III. Main Types of Transfer Pricing Documentation

3.1. Related-Party Transaction Information

The first part of the documentation process is to identify related parties and report their transactions. Businesses should keep clear information about their ownership structure, related-party relationships, and the nature of their transactions. This information helps tax authorities understand how the company is connected to other businesses within its group.

Companies should prepare records such as ownership charts, related-party lists, contracts, invoices, and transaction summaries. They should also compare the reported figures with their accounting records to make sure the information is consistent. If there are any differences, the company should investigate the cause and keep a clear explanation.

3.2. Local File

The Local File focuses on the Vietnamese company and its related-party transactions. It explains the company’s business activities, the functions it performs, the assets it uses, and the risks it takes. In addition, it describes the transactions with related parties and explains how the company determines whether its prices follow the arm’s length principle.

A Local File generally includes the following information, where required:

• Details of the Vietnamese entity and its business activities.
• Information about related parties and their relationships.
• Descriptions of related-party transactions and contract terms.
• Functional analysis covering functions, assets, and risks.
• The transfer pricing method and reasons for selecting it.
• Comparable data and financial analysis.
• Relevant financial information and supporting records.

For example, a Vietnamese manufacturer may buy raw materials from an overseas affiliate and sell finished goods to other group companies. Its Local File should explain the company’s role in production, the risks it takes, and how the pricing method supports the reported results. Therefore, the report should reflect the company’s actual business activities rather than rely on general statements.

3.3. Master File

The Master File provides an overview of the multinational group’s business and transfer pricing policies. It helps explain how the Vietnamese entity fits into the group’s global operations and how related-party transactions are managed across different countries. Where required, the document should reflect the group’s structure and business arrangements during the relevant period.

The Master File may cover:

• The group’s organizational and ownership structure.
• Its main business activities and sources of income.
• The group’s supply chain and key markets.
• Important intangible assets and related policies.
• Intra-group financing arrangements.
• The group’s overall transfer pricing policies.
• Relevant consolidated financial information.

Because the Master File often contains group-level information, Vietnamese subsidiaries may need help from their overseas parent companies to prepare it. Therefore, businesses should request the necessary information early and check that the Master File is consistent with the Local File and annual disclosures.

3.4. Country-by-Country Report

A Country-by-Country Report (CbCR) provides information about a multinational group’s income, taxes, and business activities across different countries. It helps tax authorities assess how the group’s income and tax payments are spread across the places where it operates. However, this report is required only when the applicable rules and conditions are met.

Under Decree No. 255/2026/ND-CP, a Vietnamese ultimate parent entity generally falls within the CbCR filing requirement when the group’s consolidated global revenue reaches the equivalent of EUR 750 million or more in the financial year before the reporting year. Other rules may apply when the ultimate parent company is located overseas or a surrogate parent entity files the report.

Therefore, businesses should review the group’s revenue, reporting structure, and applicable information exchange arrangements. They should also check whether the Vietnamese entity must file a CbCR or submit a notification about the entity that files it. Companies should not assume that an overseas filing automatically removes every reporting duty in Vietnam.

IV. Transfer Pricing Documentation Exemptions in Vietnam

4.1. Exemption Based on Revenue and Transaction Value

Some businesses may qualify for an exemption from preparing transfer pricing documentation if they meet specific conditions. Under Decree No. 255/2026/ND-CP, one exemption applies when both of the following conditions are met during the tax period:

• Total revenue is below VND 50 billion.
• The total value of all related-party transactions is below VND 30 billion.

However, businesses should check the full legal conditions and the reporting duties that remain applicable. In particular, an exemption from preparing transfer pricing documentation does not automatically remove the requirement to disclose related-party information.

4.2. Exemption for Businesses With an Advance Pricing Agreement

An Advance Pricing Agreement (APA) is an arrangement between a taxpayer and the relevant tax authority, or authorities, on the method used to determine transfer prices for covered transactions. Where an APA applies, a company may qualify for an exemption from preparing certain transfer pricing documents for transactions covered by the agreement, provided it meets the relevant reporting conditions.

However, transactions outside the scope of the APA may still require disclosure and supporting documents. Therefore, companies should review the agreement carefully and separate covered transactions from other related-party dealings. They should also meet the annual reporting duties linked to the APA.

4.3. Exemption Based on Business Activity and Profit Margin

Decree No. 255/2026/ND-CP also provides an exemption for certain businesses that do not earn revenue or incur costs from exploiting or using intangible assets. The company must have revenue below VND 500 billion and meet the relevant operating profit margin threshold for its business activity.

The specified profit margin thresholds are:

• Distribution: at least 5%.
• Manufacturing: at least 10%.
• Processing: at least 15%.

However, meeting the revenue and profit margin thresholds alone may not be enough. Companies should check all applicable conditions, including how revenue and costs are recorded for each business activity. They should also retain calculations and supporting records to show that they qualify for the exemption.

4.4. How Should Companies Check Eligibility?

Before claiming an exemption, businesses should review their revenue, related-party transaction values, business activities, and financial results. They should also confirm which documentation duties remain in place. This is important because different exemptions apply to different situations.

Companies should keep evidence supporting their eligibility, including accounting records, transaction summaries, financial statements, and relevant agreements. If the business does not meet every required condition, it should prepare the documents required under the applicable rules. A careful review can help prevent errors and reduce the risk of disputes during a tax inspection.

V. Deadlines and Common Documentation Mistakes

5.1. When Must Transfer Pricing Documentation Be Prepared?

Under Decree No. 255/2026/ND-CP, transfer pricing documentation must be prepared before the annual CIT return filing deadline. Businesses must then retain the documents and present them when requested by the tax authorities. Therefore, companies should not wait until they receive an audit notice before starting the preparation process.

The annual CIT filing deadline generally depends on the applicable tax rules and the company’s tax period. For businesses using a calendar tax year, the usual deadline has generally been the last day of the third month after the end of the tax year. However, companies should verify the deadline that applies to their specific filing period and any relevant changes in tax administration rules.

5.2. Missing or Incomplete Documents

One common mistake is failing to keep enough evidence to support related-party transactions. For example, a company may have a management fee agreement but no clear records showing what services it received. As a result, the company may struggle to explain the business purpose and value of the expense during a tax review.

To reduce this risk, businesses should keep relevant contracts, invoices, payment records, service reports, and internal communications. They should also explain how fees were calculated and allocated among group companies. In addition, the records should match the transactions recorded in the accounting system.

5.3. Weak Comparability Analysis

A comparability analysis helps determine whether related-party prices are consistent with those used in similar transactions between independent businesses. However, a weak analysis may rely on unsuitable companies, outdated data, or incomplete financial information. This can make it harder to support the chosen transfer pricing method.

Companies should therefore select comparable data carefully and explain why it is suitable. Under the 2026 framework, businesses should also pay attention to the prescribed priority of data sources. Where independent comparable data consists of accounting figures, companies should retain the relevant information in electronic spreadsheet format when required.

5.4. Inconsistent Financial Information

Another common problem is a mismatch between the Local File, Master File, tax returns, and accounting records. For example, the amount reported in the Local File may differ from the amount shown in the general ledger. Similarly, a group report may describe a transaction differently from the signed agreement.

To avoid these problems, companies should reconcile their records before filing. They should compare transaction values, check the consistency of financial figures, and investigate any differences. If a correction is needed, they should follow the relevant tax rules and keep records of the action taken.

5.5. Failure to Provide Documents When Requested

Businesses must be ready to provide their transfer pricing documents when the tax authorities request them. Under Decree No. 255/2026/ND-CP, the deadline for providing the documentation during the pre-inspection consultation process must not exceed 30 working days from receipt of the written request. Where there are valid reasons, an extension may be granted once for no more than 15 additional working days.

Therefore, companies should keep their documents organized and easy to retrieve. They should also assign responsibility for handling tax authority requests and coordinate with the parent company when group-level information is needed. Good document management can help the business respond on time and reduce disruption to daily operations.

VI. How to Meet Transfer Pricing Documentation Requirements

6.1. Review Related-Party Transactions Throughout the Year

Businesses should identify and review related-party transactions throughout the year rather than wait until the annual filing period. This includes checking changes in ownership, management, financing, and business arrangements. By updating their records regularly, companies can reduce the risk of missing transactions or reporting incorrect information.

They should also maintain a clear list of related parties and transaction types. In addition, the finance team should track payments, invoices, and contract changes involving group companies. This approach makes it easier to prepare the annual disclosure and supporting documents on time.

6.2. Prepare a Document Checklist

A document checklist helps companies organize their transfer pricing work and identify missing records early. It should cover the documents needed for related-party disclosure, the Local File, the Master File, and CbCR where applicable. The checklist should also include supporting accounting records and evidence for the pricing method.

A practical checklist may include:

• Related-party list and ownership chart.
• Contracts, invoices, and payment records.
• Transaction summaries and accounting reconciliations.
• Functional analysis and pricing method.
• Comparable data and financial calculations.
• Local File and Master File, where required.
• CbCR and related notifications, where applicable.
• Records supporting any exemption claimed.

Companies should review the checklist before the annual CIT filing deadline. They should also assign a person responsible for each document and confirm that the information is complete and consistent.

6.3. Coordinate With the Parent Company

FDI companies often need information from their overseas parent companies to prepare group-level transfer pricing documents. For example, the parent company may hold the Master File, group transfer pricing policy, or CbCR. Therefore, the Vietnamese entity should request the relevant information early and agree on a clear timeline.

In addition, both parties should check that the information in group documents matches the details reported in Vietnam. If there are differences in transaction values or business descriptions, they should investigate and resolve them before filing. Clear communication can help reduce delays and improve the quality of the final documents.

6.4. Review Documentation Before Filing

Before submitting the annual CIT return, businesses should review their disclosure forms and transfer pricing documents as a whole. They should check the accuracy of transaction values, the consistency of financial data, and the reasons for selecting the transfer pricing method. This review can help identify problems before tax authorities ask questions.

Companies should also confirm that they have applied the correct rules for the relevant tax period. If an exemption applies, they should keep evidence showing that all conditions are met. By completing these checks in advance, businesses can reduce filing errors and prepare for possible tax inspections.

6.5. Seek Professional Support

Transfer pricing documentation can be difficult to prepare, especially for companies with cross-border transactions, group financing, royalties, or service fees. In these cases, professional tax support can help businesses review their related-party relationships, assess documentation duties, and check the quality of their pricing analysis. It can also help identify potential tax risks before the filing deadline.

MVA Vietnam provides accounting, tax, and compliance support for businesses operating in Vietnam. Our team can help companies review related-party transactions, organize supporting documents, and assess transfer pricing compliance needs. By seeking support early, businesses can better prepare their records and respond to tax authority requests.

VII. Conclusion

Transfer Pricing Documentation Requirements Vietnam are 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 documents required under the rules that apply to their tax period. These documents may include the Local File, Master File, and Country-by-Country Report, depending on the company’s circumstances.

Since Vietnam’s transfer pricing framework changed for the 2026 tax period onward, companies should review their obligations under Decree No. 255/2026/ND-CP. They should also check documentation exemptions, prepare records before the annual CIT filing deadline, and keep supporting evidence ready for tax reviews. With careful planning and accurate documentation, businesses can reduce compliance risks and manage their tax duties more effectively.

MVA VIETNAM ACCOUNTING AND AUDITING COMPANY LIMITED