Transfer Pricing in Vietnam

Vietnam continues its economic modernisation and with it a commitment to international tax compliance standardisation. Transfer pricing, as a result, has become a critical compliance area for foreign-invested enterprises. Our guide, Transfer Pricing in Vietnam: A Guide for Foreign Investors (2025 Edition), provides a practical overview of the current legal framework, compliance obligations, and risk management strategies for businesses engaged in related-party transactions.

Key elements detailed in the guide include:

Legal Framework: Decree 20/2025/ND-CP, amending Decree 132/2020/ND-CP, reflecting Vietnam’s evolving transfer pricing regime in alignment with OECD BEPS actions.

Documentation Requirements: Detailed explanation of Forms 01–04 (Disclosure Form, Local File, Master File, and CbCR) and who must file what, by when.

Exemptions and Safe Harbors: Clarity on documentation exemptions for small-scale businesses and simplified cases based on revenue, related-party thresholds, and EBIT margins.

Transfer Pricing Methods: Practical guidance on method selection, benchmarking, and database usage (e.g., Orbis, RoyaltyStat) to substantiate arm’s length pricing.

Common Risk Factors: A checklist of red flags that may trigger tax inspections or audits, including persistent losses, payments to low-tax jurisdictions, and undocumented management fees.

Penalties and Deadlines: Overview of sanctions for non-compliance and tips on how to stay audit-ready.

The Vietnamese transfer pricing environment presents both compliance risks and strategic opportunities. Businesses that ignore documentation requirements or misidentify related-party relationships risk audits, penalties, and reputational damage. However, companies that approach transfer pricing proactively, through robust benchmarking, clear governance structures and transparent financial practices can reduce audit exposure, align global tax positions, and improve operational efficiency. As regulatory scrutiny increases, the need for accurate, timely, and well-substantiated transfer pricing documentation has never been more important.

Backed by local expertise and international experience, Alitium supports foreign investors in preparing defensible TP documentation, optimizing tax positions, and managing audit risk. Whether you are a multinational group with complex structures or a new market entrant, our team can help you meet compliance requirements with confidence.

Next Steps

If you would like obtain further assistance with your Transfer Pricing strategies or compliance in Vietnam, reach out to us on our contact page: https://www.alitium.com/contact-us/