The three-tier transfer pricing file is how the OECD and Vietnam view the same group at three altitudes: global, country and entity. From the 2026 CIT period, this framework is carried forward and updated by Decree 255/2026/ND-CP replacing Decree 132/2020 — companies still filing away old-format dossiers should review them before finalisation season.
What do the three tiers contain?
Tier one, the local file, describes the Vietnamese company itself: its organisation, business, related-party transactions, a functions–assets–risks analysis, the pricing method and the benchmarking that proves prices are arm’s length. Tier two, the master file, comes from group level: global structure, value chains, intangibles, intra-group finance and the general transfer pricing policy — the Vietnamese company must obtain it from the parent, not write it itself. Tier three, the country-by-country report (CbCR), applies only to groups above a large consolidated revenue threshold (under paragraph 1 of Article 19 of Decree 255/2026/ND-CP: consolidated global revenue equivalent to 750 million euros for the fiscal year immediately preceding the reporting year, applied from 1 July 2026; the VND 18,000 billion level in Decree 132/2020/ND-CP expired on 1 July 2026), presenting revenue, profit, tax and headcount by country. The tiers must agree: a local file calling the Vietnamese company a mere processor while the master file shows it owning key intangibles is a self-made contradiction.
Who receives each tier, and by when?
The local and master files are not filed routinely with the return; they are prepared in advance — in principle completed before the CIT finalisation deadline — and produced only when the tax authority requests them during an audit, within the statutory period from the request. CbCR, by contrast, has an active filing deadline: within 12 months after the end of the ultimate parent’s fiscal year, under a mechanism Decree 255/2026/ND-CP sets out in more detail, including local filing in Vietnam where the parent’s country has no automatic exchange mechanism with Vietnam. The annual related-party disclosure appendices to the CIT return are a separate obligation and do not replace these three tiers.
What happens if the dossier is incomplete?
Failing to prepare or produce the files on request removes the taxpayer’s ‘proof shield’: authorities may determine prices and profits on their own data, and impose administrative penalties for disclosure and documentation breaches under current tax administration rules (Law on Tax Administration 108/2025/QH15 from 1 July 2026). The fine for a documentation breach is usually far smaller than the back tax from a deemed assessment — that is the real cost. Even where Decree 255/2026 exempts a company from preparing the files, the related-party disclosure remains due in full; exemption from documentation is not exemption from proving prices when asked.
Frequently Asked Questions
What does the three-tier transfer pricing dossier contain?
A local file on the Vietnamese company and its related-party transactions; a master file on the global group supplied at group level; and a country-by-country report allocating revenue, profit and tax by country, applying only to groups above the large consolidated revenue threshold.
Who receives each tier, and what are the deadlines?
The local and master files are prepared before the CIT finalisation deadline and produced to the managing tax authority only on request during an audit. CbCR is filed actively within 12 months after the end of the ultimate parent’s fiscal year, under the Decree 255/2026/ND-CP mechanism.
What are the penalties for not filing all three tiers?
The company faces administrative penalties for documentation and disclosure breaches and, more importantly, loses the ability to prove arm’s length prices itself: authorities may deem revenue and profit to assess additional CIT with late-payment interest under the Law on Tax Administration 108/2025/QH15.
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