Transfer pricing documentation: who needs it and when

If your company transacts with related parties — a parent charging management fees, an affiliate lending capital, group purchases — Decree 132/2020/NĐ-CP almost certainly applies. The declaration forms travel with the annual CIT return, the documentation is detailed, and the reassessment risk is real.

The exemptions are narrow

A taxpayer is exempt from preparing transfer-pricing documentation only in limited cases — most notably when total revenue for the period is under 50 billion VND and total related-party transaction value is under 30 billion VND. Even exempt companies still declare their related-party relationships and transactions with the CIT return.

The three-tier file

• Local file — the detailed analysis of your Vietnamese entity's related-party transactions.
• Master file — the group's global business model, value chain and transfer-pricing policies.
• Country-by-country report — required when a Vietnam-headquartered group's consolidated revenue reaches 18,000 billion VND.

The arm's-length range tightened

Decree 132 sets the arm's-length range at the 35th to 75th percentile of the comparable set — results below the median invite adjustment. Documentation must exist before the annual CIT return is filed and be produced on short statutory deadlines when the authority requests it; "we will prepare it if audited" is not a defensible position.

We prepare defensible benchmarking and documentation, and stand with you if the authorities ask questions.