|
GUIDES · Jul 2026 · 3 min read

Transfer Pricing Advisory Services

As tax authorities increasingly step up inspections and audits of businesses with related-party transactions, complying with transfer pricing regulations is not only a legal requirement but also a

Why this matters

With tax authorities increasingly stepping up inspections and audits of businesses with related-party transactions, complying with transfer pricing regulations is not only a legal requirement but also a key factor in reducing tax risk and protecting your business interests.

With a team of specialists highly experienced in tax, accounting, and related-party transactions, we provide comprehensive transfer pricing advisory services, helping businesses meet the requirements for declaring related-party transactions, preparing transfer pricing documentation, and working with the tax authority in accordance with Vietnamese law.

What is transfer pricing?

Transfer pricing is the setting of prices for transactions between related parties, including the purchase and sale of goods, provision of services, loans, transfers of assets, cost sharing, and other financial transactions.

Under Vietnamese law, businesses with related-party transactions must declare those transactions and prepare transfer pricing documentation to demonstrate that the transactions are conducted on an arm's-length basis.

What’s included

Identifying related-party transactions
  • Review the ownership structure and related-party relationships.
  • Identify the transactions that fall within the scope of related-party transaction regulations.
  • Assess your obligations to declare transactions and prepare transfer pricing documentation.
Preparing transfer pricing documentation
  • Prepare the Local File.
  • Support the preparation of the Master File.
  • Support the review of the Country-by-Country Report (CbCR) where applicable.
  • Prepare documentation demonstrating compliance with the arm's-length principle.
Related-party transaction declarations
  • Help prepare the related-party transaction appendices required under current regulations.
  • Review the completeness and accuracy of the declared information.
  • Advise on cases exempt from preparing transfer pricing documentation.
Transfer pricing risk review and assessment
  • Assess your business's level of compliance.
  • Analyze financial ratios and the appropriateness of your intercompany pricing policy.
  • Identify potential risks that may arise during a tax inspection.
Tax inspection and audit support
  • Prepare files and explanatory documentation for the tax authority.
  • Support your business through inspections and audits involving related-party transactions.
  • Advise on resolving issues that arise and develop risk-mitigation plans.

Who it’s for

Foreign-invested enterprises (FDI).Subsidiaries of multinational groups.Businesses transacting with their parent company, subsidiaries, or other related parties.Businesses preparing for tax finalization or a tax inspection.Businesses needing a review of their related-party pricing policy and transfer pricing documentation.

Why choose Clarity for this

Expertise and practical experience
Our advisory team has experience supporting businesses across a wide range of industries, from manufacturing, trading, and services to technology and e-commerce.
Fluent in Vietnamese regulations and international practice
We combine knowledge of Vietnamese law with OECD guidelines and international practice in transfer pricing.
By your side throughout engagements with the tax authority
Beyond preparing documentation, we stand alongside your business in substantiating positions and resolving issues as they arise.
Absolute confidentiality
All client financial information, transactions, and data are kept confidential in line with professional standards and the law.
Regulatory compliance
We ensure your business fully meets the requirements for declaring related-party transactions and preparing documentation under current regulations.
Reduced tax risk
We identify potential issues early and provide appropriate solutions before the tax authority conducts an inspection or audit.
Stronger ability to substantiate your positions
We build a system of records and documentation that helps your business demonstrate the reasonableness of its related-party transactions.
Support for business decision-making
We provide in-depth insight into your intercompany transaction structure and its related tax implications.

Our commitment & responsibility

We commit to professional responsibility on every engagement — including legal liability and compensation should an error on our part occur. Your financial, personal and ownership data is handled under strict confidentiality and in line with Decree 13/2023/NĐ-CP on personal data protection.

Related knowledge

Related articles

Ready to use this service?

Talk to our specialists to get a tailored scope of work and quote.

Request this service

Related services

CallZaloGet a quote