Transfer Pricing Compliance Report

Service Scope:

• Identify related parties: China HQ, Hong Kong platform, Vietnam subsidiary, controlling persons, group companies, financing parties and service providers

• Map related-party transactions: purchases, sales, services, management fees, royalties, interest, loans, cost sharing and reimbursements

• Prepare TP disclosure forms with annual CIT filing

• Prepare Local File including functional analysis, comparables, pricing method and profit level testing

• Coordinate Master File and CbCR with China HQ or group tax team

• Design pricing policy for China-Vietnam goods trading, services, technology licensing, group loans and management fee allocations

• Review interest deduction limitation and Decree 20/2025 impact

• Prepare defense files for tax authority queries, comparable data, contracts, service evidence and commercial rationale

Process:

1. Collect group structure, ownership, management control and related-party list.

2. Summarize annual related-party amounts, contracts, invoices, payments and customs documents.

3. Determine TP filing, documentation or exemption requirements.

4. Select transfer pricing method, such as CUP, cost plus, resale price or TNMM.

5. Complete functional/risk analysis and comparable analysis.

6. Prepare annual TP forms, Local File, Master File or CbCR materials.

7. Reconcile with CIT finalization, audit report and group reporting.

8. Build China-Vietnam related-party contract, invoice, service evidence and pricing archive.