Expert perspectives | Corvane Advisory

Preparing for a transfer pricing review: six things businesses should do now

gioithieucongty10.mauwebdep.com.vn — Sat, 24 Oct 2026 15:54:35 +0000

For businesses within multinational groups, transactions with parent companies, sister entities and other related parties happen every day: purchases of materials, sales of finished goods, support service fees, royalties and intra-group loans. Transfer pricing rules require these transactions to follow the arm's length principle and to be supported by documentation. When a review comes, the difficulty is rarely a lack of data; it is that the data is scattered and the arguments have not been prepared in advance.

1. Map every related-party transaction

List all related parties, transaction types, annual values and the corresponding contracts. In practice, items such as management fees, IT cost allocations or intra-group guarantees are often missed because they do not pass through procurement.

2. Compare contracts with actual conduct

A contract may describe the business as a low-risk contract manufacturer while in practice it carries its own inventory and finds its own customers. That gap invites questions. The functions, assets and risks described in the documentation must match how the business actually operates.

3. Review multi-year results

Persistent losses or thin margins over several years while the wider group grows are usually a signal that will need explaining. Prepare a specific analysis of the causes: an investment phase, under-utilised capacity, exchange rate movements or start-up costs.

4. Refresh comparable data

The set of comparable companies should be updated regularly, with clear screening criteria. Outdated data or inconsistent selection criteria can weaken the credibility of the whole file.

5. Standardise support for intra-group service fees

Evidence that the services were actually provided: reports, email exchanges, meeting minutes.
The benefit the business received from the services.
The cost allocation basis and the mark-up applied.

6. Appoint a lead contact and prepare the narrative

Choose someone who understands both the numbers and the business to work with the review team, and prepare a set of likely questions with evidence-backed answers. Prompt, consistent responses help meetings run more smoothly.

“Good transfer pricing documentation is not the thickest file; it is the file that tells the business's real story, backed by data and evidence. Preparing early lets a business go into meetings with the tax authority with far more composure.” — Mr Ly Gia Hung, Partner, Tax Advisory, Corvane Advisory

Every business has its own transaction structure, so these steps should be tailored to its circumstances. The outcome of any review depends on many factors, but well-prepared documentation is always the foundation for presenting the business's position clearly and with support.

When to start

The best time is right after the financial year is closed, while the data is fresh and the people involved still remember the context. Businesses can allow four to six weeks to complete these steps and then update them annually rather than starting from scratch.

E-invoice compliance: a ten-point checklist before every filing period

gioithieucongty10.mauwebdep.com.vn — Sat, 24 Oct 2026 15:54:35 +0000

E-invoicing makes issuing, sending and storing invoices easier, but it also makes every error visible: data reaches the tax authority almost instantly. New e-invoice rules continue to tighten requirements on issuance timing, buyer information and how incorrect invoices are handled. Drawing on its review work for clients, Corvane's tax team has compiled ten points worth checking before every filing period.

Output invoices

1. Issuance timing matches the transfer of goods or completion of services, rather than being batched at month-end.
2. Buyer details (name, tax code, address) are checked against registration data, with particular attention to customers who have recently changed name or address.
3. Incorrect invoices are handled through the correct adjustment or replacement procedure, with a written agreement with the buyer where needed.
4. Promotional goods, gifts and internal consumption are invoiced in line with guidance and not overlooked.
5. Revenue on invoices matches revenue recorded in the books and in the return for the same period.

Input invoices

6. Invoice status is checked on the tax authority's system before the expense is recorded.
7. The seller's operating status is checked periodically, especially for new suppliers and high-value transactions.
8. Payment evidence matches the invoice: the right payee, the right amount and a compliant payment method.
9. Supporting documents (contracts, delivery notes, acceptance records) show that the transaction actually took place.

Systems and processes

10. Permissions and retention: who can issue, who can sign digitally and who can cancel; invoice data is backed up and remains retrievable for the full statutory retention period.

“The biggest e-invoice risk usually lies not in the software but in the process: goods delivered today with the invoice left for next week, or a new supplier nobody has checked. A simple checklist run consistently every period is worth far more than a year-end clean-up.” — Mr Ly Gia Hung, Partner, Tax Advisory, Corvane Advisory

Putting it into practice

Businesses can assign one person to run this checklist two to three days before each filing deadline, recording any exceptions and how they were resolved. For businesses issuing thousands of invoices a month, automated reconciliation between the invoicing system, the accounting system and bank data is worth considering.

This checklist is general guidance; how it applies depends on each business's sector and business model. Businesses should also keep up to date with new guidance from the tax authority.

Corvane's full-service clients can access this checklist as a template on Corvane Portal, with a notes column for tracking the results of each period.

Due diligence in M&A: eight red flags investors should not ignore

gioithieucongty10.mauwebdep.com.vn — Sat, 24 Oct 2026 15:54:35 +0000

Due diligence is the stage at which an investor looks inside a target business before settling on price and terms. Experience from more than 120 engagements shows that the significant issues rarely sit in the audited financial statements; they hide in the gap between reported figures and how the business actually runs. Below are eight red flags Corvane's team encounters most often.

Financial

1. Profits rise but cash flow does not. Early revenue recognition, lengthening receivables or unusual inventory build-up call for a close look at the quality of earnings.
2. Revenue concentrated in a few customers or dependent on parties related to the current owners — a risk once control changes hands.
3. Costs paid by the owners outside the books, such as management salaries or office rent, which make margins look better than they are.

Tax

4. Two sets of figures: large, unexplained differences between management accounts and tax filings.
5. Tax incentives currently enjoyed whose conditions may no longer be met after the transaction, or whose supporting documentation is incomplete.
6. Undocumented related-party transactions, or unreviewed tax years with significant transaction values.

Legal

7. Core assets not held by the company: land, trademarks, domain names or licences registered to individuals or other entities.
8. Key contracts with change-of-control clauses allowing counterparties to terminate when ownership changes; or unrecorded labour disputes and social insurance obligations.

“A red flag doesn't mean the deal has to stop. What matters is spotting it early, quantifying its impact and bringing it to the negotiating table — through price, through warranties and indemnities, or through the deal structure.” — Mr Dinh Quang Vinh, Partner, Transactions & M&A, Corvane Advisory

From findings to contract terms

Due diligence findings only add value when they are turned into specific actions. Depending on severity, an investor may adjust the price, require the seller to remedy issues before completion, hold back part of the consideration, add representations and warranties, or change the structure from a share deal to an asset deal.

Every transaction has its own context, and this list is no substitute for full due diligence. Corvane recommends that investors combine financial, tax and legal due diligence from the outset so that findings are assessed within a single picture and issues that fall between disciplines are not missed.

Allowing enough time

For a mid-sized business, combined financial, tax and legal due diligence typically takes four to eight weeks, depending on the quality of the data room and the seller's cooperation. Compressing it excessively to meet a signing date is often why important issues are missed.