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CLARITYCONSULTING
TAXFeb 20257 min read

Transfer pricing documentation: who needs it and when

Related-party transactions attract scrutiny. Understand the thresholds, the file structure and the penalties for getting it wrong.

Trần Hoàng
Head of Tax

If your company transacts with related parties, transfer-pricing rules likely apply. The documentation is detailed and the penalties are real.

Thresholds

Exemptions exist for smaller companies and limited related-party volumes — but they are narrow.

The three-tier file

Local file, master file and country-by-country report each serve a purpose. Most Vietnamese entities focus on the local file.

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

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About the author
Trần Hoàng
Head of Tax

Specialist in corporate tax, transfer pricing and tax-authority representation, with 15+ years advising Vietnamese and FDI businesses.

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