Transfer Pricing in Vietnam: A Guide for Singapore Groups
If a Vietnam company trades with its Singapore parent or another related company, it should check three things: who the related parties are, what transactions took place, and which declarations and records it must prepare. It should also keep evidence that supports each charge.
Legal information reviewed: 7 October 2026.
What Is Transfer Pricing in Vietnam?
Transfer pricing refers to the prices used in transactions between related parties. These transactions may involve goods, services, loans or intellectual property. Vietnam’s rules ask companies to assess whether their terms reflect those that independent businesses might agree.
What counts as a related-party transaction?
Start with the relationship between the parties. Ownership may create a related-party relationship. Control, management or certain financing arrangements may also do so. Next, identify the transactions between them.
Example: A Singapore parent owns a Vietnam company and charges it for finance support. The Vietnam company should review both the relationship and the service fee. A payment to an unrelated Singapore supplier does not become a related-party transaction simply because it crosses a border.
Why does an arm’s-length price matter?
An arm’s-length price reflects terms that independent parties might agree in similar circumstances. The Vietnam company should be able to explain what it received and how the group set the charge. A group price list can help, but it does not prove that a particular fee suits the Vietnam company.
Which Business Arrangements Should Companies Review?
Transaction | Documents to collect | Main question |
Management and shared-service fees | Agreement, service description, fee calculation, invoices and proof of work | What service did the Vietnam company receive, and how did it benefit? |
Intercompany loans and interest | Loan agreement, interest calculation, repayment schedule and payment records | How did the group set the loan terms and interest charge? |
Royalties and technical support | Licence or support agreement, fee calculation and evidence of use or delivery | What rights or support did the Vietnam company receive? |
Goods bought or sold within the group | Contracts, product details, invoices and shipping records | Can market evidence support the price and terms? |
Does Your Vietnam Company Have Transfer Pricing Obligations?
Identify the parties and transactions
Map the group’s ownership and control. List the companies that provide goods, services, loans or rights to the Vietnam business. Update this list when the group changes its structure or financing.
Check declaration requirements
Check what the Vietnam company must declare with its annual corporate income tax finalisation. The current rules require companies to assess their related-party relationships and transactions. Do not assume that an exemption from preparing a transfer pricing file also removes the declaration requirement.
Check documentation requirements and exemptions
Next, determine whether the company must prepare and retain a transfer pricing file. Some companies qualify for an exemption if they meet the applicable conditions. An exemption does not remove the need to keep reliable records for real transactions and tax deductions. Assess the rules for the tax year being filed.
What Should a Transfer Pricing File Demonstrate?
The file should explain why the transaction took place, what each party did and how the group set the price. Its figures should match the contracts, invoices, payments and accounting records.
For a management fee, keep the agreement, work outputs, fee calculation, invoice and payment proof together. Match the service period across the documents. A contract shows what the parties agreed to do; evidence of delivery shows what they actually did.
VINEX’s view: Review recurring group charges during the year. Ask the Vietnam team who requested each service, what work it received and where it stores the evidence. These answers become harder to reconstruct at tax finalisation.
VINEX’s Accounting Documentation in Vietnam article explains how to organise supporting records for service fees and other expenses.
How Does Transfer Pricing Interact With Other Vietnam Taxes?
Corporate income tax
A supported transfer price does not automatically make an expense deductible. The company must also check the tax conditions for that expense and keep evidence of its business purpose.
Foreign contractor tax
A payment to a Singapore company may need a separate foreign contractor tax review. That review concerns the payment’s tax treatment. Transfer pricing concerns the terms between related parties. The same payment may raise both questions.
Accounting and tax reviews
The amounts in tax declarations should match the company’s books and transaction records. Resolve differences while the people and documents are still available. VINEX’s Vietnam Tax Compliance 2026 article covers the wider reporting framework.
Common Transfer Pricing Risks for Singapore–Vietnam Groups
Management fees with little service evidence: An invoice alone may not show what work the parent company performed or why the Vietnam company needed it.
Applying a group policy without a Vietnam review: A regional policy explains the group’s approach. The Vietnam company still needs to check its own charges and records against local requirements.
Waiting until year-end: A late review can leave gaps in work records, cost allocations or loan documents. Check material transactions during the year.
Using outdated rules: Vietnam issued new transfer pricing rules in 2026. Check the rules that apply to the tax year under review before reusing last year’s forms or exemption analysis.
A Practical Transfer Pricing Review Checklist
Map related parties.
List transactions.
Collect contracts, invoices, work evidence and payment records.
Review how the group set each charge.
Check the declaration and file requirements.
Assign someone to resolve missing records before tax finalisation.
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Frequently Asked Questions
Does a Singapore parent automatically create transfer pricing obligations in Vietnam?
The ownership link may make the companies related parties. The Vietnam company must then identify its transactions and assess the rules for the relevant tax year.
Do small companies need a transfer pricing file?
Some companies may qualify for an exemption, but size alone is not enough to decide. Check every condition and any remaining declaration duties.
Are management fees paid to a parent company deductible?
Not automatically. The Vietnam company should keep evidence of the service, its business purpose, the fee calculation and payment.
Is transfer pricing the same as foreign contractor tax?
No. They address different tax questions. A payment to a foreign related company may require both reviews.
When should a company prepare its records?
Collect evidence when each transaction occurs. If the company must prepare a transfer pricing file, it should complete the file before filing its annual corporate income tax finalisation.
How VINEX Can Help
VINEX can help map group transactions, review contracts and accounting records, and coordinate issues with the company’s tax specialists. Its Finance and Accounting Outsourcing in Vietnam article explains how ongoing accounting support can help organise those records.
To start a review, share the group structure, a list of charges involving the Vietnam company, the main agreements and the tax year you need to assess.
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