Consulting services for related-party transaction documents in Lam Dong Province
Consulting services for related-party transaction documentation in Lam Dong Province — helping businesses comply with Decree 132, reduce tax risks, and standardize internal pricing policies.
1. Introduction to related party transaction documentation consulting services in Lam Dong Province
- According to Decree 132/2020/ND-CP, related-party transactions are transactions between related parties (e.g., branch – parent company, company within the same group), including the purchase and sale of goods, provision of services, transfer of intangible assets, or internal allocation of expenses. These related-party transactions require proof of transaction prices that conform to market principles to reduce risks with the tax authorities.
- Common types of tax return files include Local files, Master files, and Country-by-Country reports (CbCR)—each serving a different purpose in analysis and reporting to tax authorities. PMH assists in drafting each file type to suit the size and relationships of your business .
- Why do businesses need to create a price determination file? A price determination file helps demonstrate the basis for determining transaction prices , clarifies the relationship between the parties involved , and reduces the risk of adjustments, tax audits, or administrative penalties. For example: a branch in Ho Chi Minh City selling goods to the parent company without justification for the price – when the tax authorities conduct an audit, the business is easily suspected and may have its taxable income adjusted. If you want to know whether your business needs to create a price determination file, PMH is ready to provide free consultation and conduct a case-by-case review.
2. When does a business need to create a related-party transaction record?
- Foreign-invested enterprises (FDI) that conduct transactions with their parent company, affiliated companies, or related parties are often subject to review and documentation of related-party transactions — this is one of the most common scenarios .
- Domestic businesses must also keep records when internal transactions exceed prescribed thresholds (in terms of total value or frequency) — for example, buying and selling goods between companies within the same system or providing internal services at unusually high prices compared to market rates.
- When requested by the tax authorities during an audit or inspection, businesses must submit local files, master files, or related declarations (e.g., declaration forms as per current guidelines). Note: forms and thresholds may be updated, so it is necessary to check the latest legal documents.
- When signs of transfer pricing risk emerge—for example, unusually low or slightly high prices between related parties compared to the market, disproportionately fluctuating profits, or undocumented transactions—that’s when a business should seek advisory services to review and prepare complete documentation.
Short checklist: warning signs — unusually low profit margins, high internal expense ratios, transactions without clear contracts, sudden revenue fluctuations between related parties. If you see one or more of these signs, please send us preliminary data for a free review and specific recommendations.
3. Legal basis for related-party transactions
- The primary legal framework for related-party transactions in Vietnam is Decree 132/2020/ND-CP and its related guiding circulars. These documents define the concept, methods for determining transaction prices, required documentation, and the reporting responsibilities of enterprises when conducting transactions with related parties .
- thresholds and regulations for filing: Decrees and accompanying circulars stipulate criteria (by transaction type, total value , or frequency) to determine when a Local file/Master file must be created. Since thresholds may be adjusted in new regulations, businesses should check the updated guidance documents before making a decision.
- Declaration and record keeping: When requested by the management agency or tax authority , businesses must submit declaration forms, reports, and documents as instructed (e.g., declarations/forms prescribed by Decrees and Circulars). Maintaining complete records facilitates declaration , reporting, and explanation during inspections.
Legal Note: The above presentation is for guidance only. For accurate application to each specific case, it is necessary to consult updated decrees and circulars — PMH assists in researching and citing specific provisions if your company requests it. See the official sources on the Legal Information Portal or contact our consulting department for detailed support.
4. Job description in the related-party transaction document consulting service in Lam Dong Province
Review and classify transactions :
we help identify transactions involving the purchase and sale of goods, provision of services, transfer of intangible assets, and allocation of internal costs between related parties ; we compile a list of related parties, categorized by ownership/control relationship, to determine the scope of documentation for each business .
Functional-risk-asset analysis and pricing :
Applying international standard methods (CUP, Cost Plus, TNMM, resale) to provide arguments for determining a transaction price that is consistent with the company’s actual operations . The analysis includes: who produces, who distributes, who provides the service, the level of risk, and the assets involved to select appropriate comparison and benchmarking methods.
Prepare local files:
create detailed local documents including transaction descriptions, comparative analysis, relevant financial data, contracts, internal reports, and justifications for determining the transaction price to facilitate audits by regulatory and internal corporate governance bodies . Reference deliverables: analysis report (20–30 pages) + complete local files (PDF/Excel checklist).
Support in creating Master files and CbCRs (if needed):
For businesses belonging to multinational corporations, PMH compiles information to create corporate profiles (Master files) and Country-by-Country reports, ensuring consistency between local and corporate profiles according to international and domestic regulations .
Review and Declaration of Related Party Transactions:
We review the forms for declaring related party transactions (according to current guidelines) to ensure accurate declarations, avoid errors, and reduce the risk of tax arrears and penalties. We help complete the forms and explain the data fields that need to be filled in.
Consulting on pricing and accounting policy adjustments:
Based on the analysis results, PMH proposes adjustments to pricing policies, cost allocation methods, and accounting to ensure internal pricing transparency , reduce transfer pricing risks, and guarantee tax compliance.
Practical example (summary):
A **FDI** company has an internal service transaction with its parent company — PMH performs functional analysis, selects the TNMM pricing method , and collects data. Financial analysis over 3 years and benchmark comparison; the result is the creation of a Local file, proposed adjustments to pricing policies, and support for tax declaration, helping businesses reduce the likelihood of upward adjustments to their taxable income . Reference time: Standard package completed in 3–6 weeks (depending on the volume of the business and the number of transactions to be analyzed).
If your company requires a quote or wishes to submit documents for accurate evaluation, please contact PMH so we can provide a proposal report with service costs tailored to the scope of work.
Required data checklist (sample)
| Data type | Purpose of data usage | Example / Request |
| Financial statements & accounting records | Provides a basis for analyzing profit margins, costs, and making year-on-year comparisons. | Annual financial statements (for the last 3 years, if available), detailed ledgers, and bank statements — (Required) |
| Contracts, partnership agreements | Provide proof of the transaction terms, payments, and pricing conditions. | Internal service contracts, sales contracts, cost allocation agreements — (Required if applicable) |
| Market data & comparisons | Used for benchmark analysis when determining price. | Reference price list, industry report, comparative data — (Depending on the case) |
| List and description of stakeholders | Identify ownership, control, and roles in the transaction. | List of shareholders, ownership chart, job descriptions — (Required) |
| Describe the business operations and products/services. | Clarifying the basis of price formation, value chains, and competitive factors in the market. | Description of production and distribution processes, product catalog — (Required) |
Note: The table above lists commonly used basic data sources when creating a profile. PMH recommends adding a “Required” column (Mandatory / Optional) as in the example above so that businesses know their priorities for preparation. To ensure security when submitting data , your company can use our secure upload portal or send it via encrypted email. If needed, PMH provides a downloadable checklist template and detailed instructions upon request.
5. Service process at PMH
- Receiving documents, declarations, and financial data — Initially, we will send a detailed checklist to help your company prepare all the necessary data. Estimated time: 1 week (depending on the volume of data).
- Review and classify related-party transactions — we examine the relationships between parties, classify transactions by type (goods, services, intangible assets, cost allocation), and assess the risks. Deliverable: transaction classification table + preliminary risk report. Estimated time: 1–2 weeks.
- Prepare analytical reports and documentation — including functional ‑risk analysis of assets, method selection and transaction pricing , data collection for comparison, and preparation of appropriate local/master files. Deliverable: Analytical report (20–30 pages) + complete local files. Estimated time: 2–4 weeks (depending on complexity).
- Handover & Submission as per Regulations — PMH assists in completing documentation for submission to regulatory authorities or internal archiving as required by the decree . We provide guidance on archiving, file formatting, and internal control checklists.
- Participating in tax audits/inspections — PMH can represent or support the accounting team in presenting arguments, providing documents, and responding to requests from tax authorities . The scope of representation must be clearly agreed upon in the consulting contract.
Suggested general timeline (for reference): Receipt & checklist (1 week) → Review & classification (1–2 weeks) → Analysis & document preparation (2–4 weeks) → Handover & submission support (1 week). These milestones may vary depending on the volume of data and the number of transactions for the business.
Typical deliverables include: data checklist (Excel), analytical report (PDF), complete local/master file (PDF/Word), summary of pricing policy and accounting instructions. If your company wishes to submit a preliminary proposal , PMH will respond within 48 hours to determine the scope of work and provide a detailed quote .
6. Benefits of using related party transaction documentation consulting services in Lam Dong Province
- Compliance with legal regulations: This service helps businesses build documentation in accordance with Decree 132 and related regulations , reducing the risk of administrative penalties or tax arrears when tax authorities conduct audits.
- Reducing the risk of being assessed for income tax : Clear pricing documentation and analytical reports help demonstrate the basis for calculating transaction prices , thereby reducing the likelihood of tax authorities adjusting corporate income tax upwards and collecting back taxes or penalties for late payment.
- Internal pricing policy transparency: When affiliated parties have clear and documented pricing policies , it increases financial transparency, building trust with the parent company, investors, and regulatory authorities.
- Long-term cost savings: The cost of using professional record-keeping services is often lower than the cost of back taxes, fines, or having to adjust accounting records during an audit — preventative investment is often cost-effective for businesses .
7. The role of internal/corporate accounting
- Data and documentation preparation: internal accountants provide financial statements, ledgers, contracts, agreements, and related data to support analysis and determine transaction prices .
- Timely coordination and information provision: Rapid coordination between internal accounting and the consulting team helps shorten record-keeping time and ensures complete and accurate data—especially important for businesses with many internal transactions .
- Implementing the recommendations following the consultation: accountants are responsible for making adjustments to pricing policies, cost allocation, and accounting practices according to the guidelines to ensure consistency in financial reporting and tax filings.
Anonymized example: A manufacturing company, after implementing PMH’s recommendations, completed its documentation and reduced the probability of being subject to back taxes during an audit from a high-risk to a low-risk level – resulting in cost savings and operational stability. Suggestion for accountants: Prepare financial statements (for 3 years), internal contracts, a list of stakeholders, and a summary of pricing policies in advance so PMH can quickly analyze them.
8. Risks of not documenting related-party transactions
- Corporate income tax assessment : If the tax authorities determine that the transaction prices between related parties do not reflect market prices, the company may have its taxable profit adjusted upwards.
- Tax arrears and administrative penalties: Businesses may have to pay additional taxes , fines, and late payment penalties if their records are incomplete or inaccurate—the financial consequences could outweigh the cost of filing the records in the first place.
- Being classified as high-risk for tax purposes means businesses may face more frequent audits and inspections, damaging their reputation with regulators and investors, and disrupting business operations.
- Impact on management decisions: Tax risk reduces internal bargaining power, affecting pricing policies and the long-term profitability of the business .
9. Related administrative penalties
- Penalties for failing to prepare or provide documents when requested by the tax authorities — the amount of the penalty depends on current regulations and may include back taxes.
- Penalties for providing false or incomplete information in the related-party transaction declaration form — leading to the risk of reporting adjustments and tax arrears.
- Tax authorities will collect back taxes and impose late payment penalties if, after an audit, they adjust the company’s taxable income upwards.
Illustrative example (summarized, anonymized): A foreign direct investment (FDI) company provides internal services to its parent company; due to a lack of functional analysis documentation and transaction pricing justification , the tax authorities adjusted the taxable revenue upwards, resulting in nearly double the annual expenses of the relevant department. This case demonstrates that the cost of post-audit resolution is often significantly higher than the cost of using the documentation preparation service from the outset.
If your company wishes to assess transfer pricing risks and determine the level of documentation required, PMH offers free preliminary data review (e.g., financial statements, internal contracts, transaction lists) and provides a response within 48 hours with a proposal for a suitable filing plan to minimize risks related to taxes and corporate income tax .
10. PMH’s Commitment
- With a deep understanding of Decree 132/2020/ND-CP and related international regulations , the PMH team of experts regularly updates their knowledge of legal documents to provide accurate and timely advice in accordance with current regulations.
- Practical experience with FDI companies and corporations — PMH has assisted many businesses in reviewing related-party transactions , determining transaction prices , and preparing Local/Master documents in accordance with international standards.
- Strict data security: all financial and contract data is stored, transmitted, and processed securely in accordance with privacy policies and confidentiality agreements with clients.
- Support in explaining matters to tax authorities : PMH accompanies businesses when explanations are needed, providing arguments, documents, and participating in authorized work or providing professional advice to defend the business’s pricing position.
11. Cost of consulting services for related-party transaction documents in Lam Dong Province
- Factors influencing costs include : the size of the businesses , the number and type of related-party transactions , the complexity of functional analysis, and the volume of data to be collected—these factors determine the workload required for profiling and pricing .
- Transparent pricing policy: PMH offers both comprehensive packages (review, analysis, document preparation, and short-term explanation support) and individual task-based pricing, giving companies flexibility in choosing.
- Service Package Illustration (for reference) — the table below describes the scope and target audience for each service package . To receive a specific quote based on your company’s service scope , please send a transaction summary and preliminary data for a quick quote.
| Service package | Scope of services | Suitable candidates |
| Basic Package | Review transactions, data checklists, risk reports, and quick recommendations. | Small businesses with few related-party transactions. |
| Standard Package | Perform functional analysis, select a pricing method , and create a local file. | Medium-sized enterprises and FDI companies have many transactions. |
| Comprehensive Package | Prepare Local/Master/CbCR (if needed) documents and assist with explanations to the tax authorities . | multinational corporations and businesses |
Note: The actual cost will be quoted by PMH after assessing the service scope and workload. A reference price can be provided once your company submits the scope of work and initial data — PMH is committed to transparent pricing and prompt responses.
12. Frequently Asked Questions (FAQ)
- What types of related-party transaction documents are there?
There are typically three main types of files: Local files, which detail transactions and the rationale for determining the company’s valuation in Vietnam; Master files, which summarize information about the group; and Country-by-Country reports (CbCR), which report the allocation of profits by country. Depending on the circumstances and scale, a business may need to create one or more of these files. See the “Job Description” section for specific deliverables (analysis reports, Local file PDF/Excel checklist).
- Do small businesses need to file a record?
Depending on the prescribed thresholds and conditions: if the total value or frequency of related-party transactions exceeds the threshold stipulated by the Decree/Circular, documentation is required; otherwise, it may be exempt. To determine the exact situation of your company, please send us preliminary data for a free check (see the checklist for required data).
- When are businesses exempt from filing documents?
There are some exceptions as stipulated by regulations (for example, businesses with no related-party transactions or transactions that do not exceed the threshold). However, “exemptions” only apply when all specific conditions are met. PMH supports verifying the actual data and providing clear answers regarding exemptions (quick response after receiving preliminary data).
- What are the penalties for not creating a record?
Businesses may face administrative penalties, tax arrears , and late payment penalties if the tax authorities determine errors. The specific penalty amount depends on the severity of the violation according to current regulations — therefore, keeping complete and timely records is an effective preventative measure.
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Does PMH provide support in explaining matters during tax audits?
Yes. PMH assists in preparing arguments and documents, participates in explanations and works with tax authorities as authorized, or provides professional advice throughout the inspection/audit process. The scope of representation and support will be clearly stated in the service contract.
- What does PMH’s free checkup include and how long does it take?
The free audit service is a preliminary assessment based on concise data: financial statements (1–3 years), key internal contracts, and a list of related-party transactions. Upon receiving the data, PMH will respond within 48 hours with a basic risk assessment and a suitable service package proposal. Further in-depth analysis will be quoted separately.
- I want to do some self-review before contacting them — does PMH have a checklist?
Yes. PMH provides a sample data checklist (financial statements, contracts, market data, stakeholder list, activity description) for businesses to review beforehand. You can download the checklist or request a sample file via email.
If you have any further questions, please refer to the relevant sections in this article (Procedure, Checklist, Costs) or contact us directly for specific advice. PMH is ready to assist all businesses in preparing documents and providing explanations to the tax authorities.
13. Call to Action (CTA)
- Contact PMH now for professional advice on related-party transaction documentation services — send us a transaction summary, we will conduct a preliminary review and respond within 48 hours with guidance on data preparation and a suitable package proposal.
- CTA: Register for a free consultation — or call our hotline/Zalo (please refer to the contact page) to receive a document checklist and a price quote for our company ‘s services .
Note: PMH provides consulting services, document preparation, and support in explaining matters to the tax authorities — if you require representation or a detailed quote, please provide the scope of the transaction and initial data so we can advise you specifically.
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Quoc Dat
