News about transfer pricing

The Quốc Dân Hiểu Thuế programme, broadcast on October 11, 2026, proposed raising the revenue threshold for exemption from related-party transaction filing from under VND 200 billion to under VND 500 billion, and clarified that transfer pricing is not the same as tax evasion. According to Tô Kim Phượng of the Tax Department, transfer pricing becomes improper only when related-party dealings do not follow market prices and reduce the tax payable. Bùi Ngọc Tuấn of Deloitte Vietnam noted that companies below the threshold must also have no intangible asset transactions within their group and meet net profit margins of 10% for manufacturing, 15% for processing and 5% for distribution. Exemption from filing documentation does not exempt companies from declaring related-party information under Appendix 1 of Decree 132. If documents are deemed unreasonable, tax authorities may set the profit margin and collect additional tax plus a 20% penalty on the amount assessed.