Tax, transfer pricing & inspections

Tax treatment of related-party transactions needs a complete supporting record

Decree 255/2026/ND-CP applies from the 2026 CIT period. Loans and capital movements with controlling individuals, the documentation exemption and CbCR rules have all changed – and tax inspections look at customs, accounting and transfer pricing together.

• 01 The related-party map has not been rebuilt under the Decree 255/2026 tests, including borrowing and in-year capital transfers.
• 02 Intercompany services, royalties or loans may be challenged on benefit, pricing or deductibility.
• 03 A tax inspection or audit notice has arrived and the supporting records sit with different teams.
• 04 Historical exposures need to be quantified – non-deductible costs, VAT invoice risk – before the authority asks.
• 05 Group CbCR responsibilities are unclear – who notifies, who files, and by when.

From data request to a position you can defend

1. 01 Scope and data request. Intercompany agreements, invoices, ledgers, group information and prior filings.
2. 02 Map and analyse. Related parties, transactions, functions and risks; exposures quantified.
3. 03 Document. Transfer-pricing file and memoranda for each sensitive position.
4. 04 Support the review. Explanations and records prepared before and during inspection.