Vietnam Transfer Pricing Documentation Requirements
Vietnam requires a Master File and Local File from taxpayers with related-party transactions, exempting small taxpayers below revenue and transaction thresholds, and requires transfer pricing disclosure appendices to be filed with the annual corporate income tax return. Local comparables are required where available.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Taxpayers with related-party transactions; exempt below VND 50bn revenue and VND 30bn related-party transactions | By tax return filing date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | VI | Yes (administrative fine; reassessment of profits) |
Local File Required | Same exemption thresholds as the Master File | By tax return filing date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | VI | Yes (administrative fine; reassessment of profits) |
TP appendices Disclosure appendices
Annual filing | Taxpayers with related-party transactions | With the CIT return (within 3 months of year-end) | Submission deadline The documentation must be filed with the tax authority by the date shown. | VI | Yes |
CbC report Required | Group revenue ≥ VND 18,000,000m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
Calculate your exact Vietnam deadline
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Scope of the documentation obligation
A Vietnamese taxpayer with related-party transactions must prepare a Master File and Local File. Small taxpayers are exempt, where annual revenue does not exceed VND 50 billion and the total value of related-party transactions does not exceed VND 30 billion, and a further exemption applies to taxpayers performing only routine functions within set margin bands. The documentation is held available by the return filing date, and transfer pricing disclosure appendices are filed with the annual corporate income tax return, which is due within three months of the financial year-end.
Distinctive features of the Vietnamese regime
The defining feature of the Vietnamese regime is the disclosure-appendix structure attached to the corporate income tax return. The appendices include information on related parties and related-party transactions and a checklist of the information required for the Local File, so the return itself signals the taxpayer’s documentation position before any request. The administrative fine for an omission to file is modest at VND 5 million, but the larger exposure is the reassessment of transfer prices or profits where the taxpayer fails to comply with the arm’s length principle and the documentation requirement. There is no general safe harbour beyond the small-taxpayer exemptions.
Benchmarking and comparables
There is a legal requirement to use local comparables; where none is available, comparables from other countries in regions with comparable industry conditions and levels of economic development are acceptable. Single-year testing is required, and the tax authority prefers single-year testing in audits. A fresh benchmarking search is not specifically required every year, but an annual comparability review and financial update must be performed. The limitation period for tax collection is ten years from the date the offence is found, with no limitation where the taxpayer did not register for tax.
Frequently asked questions
Which Vietnamese taxpayers are exempt from preparing documentation?
Small taxpayers with annual revenue not exceeding VND 50 billion and related-party transactions not exceeding VND 30 billion, and taxpayers performing only routine functions within the set margin bands.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.