Transfer pricing is a pervasive tax issue among multinational companies. In Vietnam, the tax authorities require special documentation to report related party transactions.

At Grant Thornton Vietnam, we assist our valued clients in an expanded scope of services, from meeting the Vietnamese compliance requirements to proactively planning your business, aiming to achieve both operational and tax supply chain effciencies. Compliance with transfer pricing regulations is an important aspect of doing business effectively in Vietnam as failure to do so may result in significant penalties.

Approaches and services:

Your business: Market entry

Service 1: Advisory

Grant Thornton’s solutions:

  • Acknowledge the current Transfer Pricing environment and impact on business
  • Provide professional advice on the prospective transactions with related parties and Transfer Pricing positions.

Timeline: 1-3 weeks.

Deliverable: Our advisory memo containing key findings, potential risks, and recommendations for future improvement.

Your business: Plan your business

Service 2: Planning and review

Grant Thornton’s solutions:

  • Plan the appropriate approach and testing method for the transactions between related parties
  • Review the Transfer Pricing materials that have been prepared from the Vietnamese Transfer Pricing perspective.

Timeline: 2-4 weeks

Deliverable: Our review memo, providing professional advice to meet the Vietnamese legal requirements.

Your business: Compliance

Service 3: Compliance assistance

Grant Thornton's solutions 

  • Assist in preparation of the compliant documents in accordance with the Vietnamese Transfer Pricing legal framework;
  • Document the explanations for loss and/or low profitability based on the provided information.

Timeline: 4-6 weeks.


  • Annual Transfer Pricing Disclosure Form
  • Transfer Pricing Documentation report
  • Transfer Pricing Master File
  • Advance Pricing Agreement

Your business: Wind-up disposal

Service 4: Audit assistance

Grant Thornton's solutions: 

  • Assign a team of professionals to assist with Transfer Pricing audits;
  • Provide proper responses to defend the Transfer Pricing position against the queries/ challenges from tax authorities.

Timeline: 1-2 weeks.

Deliverable: Suggestions for negotiation with the local tax authority

How we can help