International Business Advisory (IBA)

Harmonizing overseas corporate ERP logic with Vietnamese statutory standards (Circular 99/2025/TT-BTC), structuring defensible transfer pricing under Decree 255/2026/ND-CP, and designing cross-border capital solvency structures.

Core Service Areas

1. Circular 99/2025/TT-BTC & Enterprise ERP Architecture Transition

For multinational groups operating under centralized parent-company ERPs (SAP, Oracle, Kingdee), IPAS designs the accounting structure and reporting mappings needed for the group system to meet Vietnamese statutory requirements. We configure statutory compliance directly into core systems—eliminating shadow ledgers, secondary local software, and manual double-data entry.

• COA Master Blueprint: Standardizing a compliant 3-tier Chart of Accounts under Circular 99/2025/TT-BTC, cross-referenced to historical Circular 200 ledgers.
• Transaction Mapping Master Matrix: Defining deterministic Debit/Credit rules across multi-scenario business events.
• Statutory Financial Statement Formula Matrix: Designing automated data retrieval rules for Forms B01-DN, B02-DN, and B03-DN, resolving dual-nature account gross presentation.
• Pre-Go-Live UAT Assurance: Conducting formula workshops and test-environment testing on sample operational datasets prior to cutover.

See Selected Experience.

2. Transfer Pricing Framework & Regulatory Documentation (Decree 255/2026/ND-CP)

Transfer pricing compliance at IPAS is designed as a consistent evidence framework: mapping transaction substance → establishing arm's-length economics → compiling audit-ready supporting documentation.

• Related-Party Value Chain Mapping: Analyzing intercompany service allocations, technical royalties, and corporate capital loans under Article 5 thresholds of Decree 255/2026/ND-CP.
• Economic Benchmarking & FAR Analysis: Functions–Assets–Risks characterization paired with local and regional commercial database benchmarking.
• Statutory Documentation Dossier: Compiling Local File (TP documentation), Master File, and audit-ready explanatory memoranda to withstand rigorous tax inspections.

3. FDI Capital Architecture & Investment Licensing Coordination

• Investment Term Extension & Solvency Assessment: Formulating integrated financial forecasts, equipment technical viability evaluations, and parent-guarantee dossiers to secure investment term extensions before Provincial Departments of Finance.
• FDI Capital & SBV Compliance: Structuring direct investment capital accounts (DICA), foreign loan registrations with the State Bank of Vietnam, and capital adjustments under Enterprise Law.
• Expatriate Tax Structuring: Personal income tax planning for foreign executives: tax residency determination, dual-contract risk assessment, and annual statutory finalization.