Core Service

Transfer pricing in Vietnam for foreign companies

Local File, Master File, CbCR, benchmarking, and TP audit defence. Compliant with Decree 132/2020 and OECD BEPS.

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Overview

Vietnam's transfer pricing regime is one of the most active in the region. The GDT routinely audits inter-company transactions and can reassess CIT, VAT, and FCT for multiple years. Our transfer pricing service covers the full compliance cycle: Local File, Master File, CbCR, benchmarking, and TP audit defence.

Who needs this service

  • FDI companies with related-party transactions of VND 50 billion or more per year
  • Multinational groups with material Vietnam operations
  • Companies under TP audit or inspection by the GDT
  • Joint ventures with cross-border flows

Legal requirements

Local File

Required for companies with related-party transactions of VND 50 billion or more per fiscal year. Due by CIT finalisation deadline.

Master File

Required for groups with consolidated revenue of VND 18,000 billion or more. Due by CIT finalisation deadline.

CbCR

Required for groups with consolidated revenue of VND 18,000 billion or more. Filed with the GDT for the parent's fiscal year.

Threshold declarations

All companies must file an annual declaration disclosing whether the TP thresholds are met.

Pricing

Indicative fees

ItemFee
Local Filefrom USD 5,000
Master Filefrom USD 8,000
CbCR notificationfrom USD 1,500
Benchmarking studyfrom USD 3,000
TP audit defencefrom USD 10,000 per audit

Fees are indicative and depend on transaction volume, complexity, and reporting requirements. Request a tailored proposal.

Timeline

Typical engagement timeline

Phase 1 · Week 1–3

Data collection

Inter-company transactions, agreements, financial data.

Phase 2 · Week 4–8

Documentation

Local File / Master File / CbCR preparation, benchmarking.

Phase 3 · By CIT finalisation deadline

Submission

Local File / Master File available on request; CbCR filed with CIT return.

Watch out

Common mistakes we help you avoid

  • 01Treating the Local File as a year-end project rather than a contemporaneous process
  • 02Using a single comparable for the benchmarking (insufficient)
  • 03Failing to update the Local File when the business changes
  • 04Not aligning the TP documentation with the inter-company agreement
Why us

What you get

Audit defence

We represent you in TP audits, presenting the documentation and negotiating adjustments.

Risk reduction

Contemporaneous documentation reduces the GDT's ability to reassess and the penalties that follow.

Cross-border alignment

Documentation aligns with OECD BEPS and supports your group's global TP policy.

FAQ

Frequently asked questions

Do all FDI companies need a Local File?
A Local File is required for companies with related-party transactions of VND 50 billion or more in a fiscal year. Below the threshold, preparation of a contemporaneous file is best practice and reduces audit risk.
What is the typical Local File timeline?
A Local File is prepared within 3–6 weeks of the fiscal year-end and is ready by the CIT finalisation deadline. A Master File takes 6–10 weeks due to group-level data collection.
How much does transfer pricing documentation cost?
A Local File for a single Vietnamese entity typically costs USD 5,000–12,000. A Master File for the group is USD 8,000–18,000. CbCR notification is USD 1,500–3,000. A full benchmarking study is USD 3,000–8,000 depending on the number of tested parties.
What is a TP audit defence?
A TP audit defence is the representation of the company before the GDT in a transfer-pricing review. It includes responding to information requests, presenting the documentation, negotiating adjustments, and appealing assessments.
Get Started

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Free 30-minute consultation. We'll review your situation and outline a fixed-fee engagement.

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