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Circular No. 89/2026/TT-BTC - the 839-Page “Super Circular” Consolidating Guidance on the Law on Tax Administration, Effective from 1 July 2026

7/31/2026
Circular No. 89/2026/TT-BTC

On 30 June 2026, the Ministry of Finance issued Circular No. 89/2026/TT-BTC providing detailed guidance on the Law on Tax Administration No. 108/2025/QH15 and Decree No. 252/2026/ND-CP, effective from 1 July 2026 (Clause 1, Article 99 of Circular No. 89/2026/TT-BTC). At 839 pages, it is one of the longest circulars ever issued in the field of tax administration, affecting virtually every enterprise, household business and individual with tax obligations in Vietnam.

Key New Developments for Enterprises

1. Quarterly PIT declarations for salaries and wages officially introduced.

Under Point a.1, Clause 1, Article 22 of Circular No. 89/2026/TT-BTC, organisations and individuals paying income from salaries and wages must declare the PIT withheld on a quarterly basis. Under Point a.2, Clause 1, Article 22, they must also conduct annual tax finalisation and finalise tax on behalf of individuals who have provided authorisation, regardless of whether any tax was withheld. Accordingly, the monthly PIT declaration mechanism previously prescribed in Article 9 of Decree No. 126/2020/ND-CP, as amended and supplemented by Clause 1, Article 1 of Decree No. 373/2025/ND-CP, no longer applies, significantly reducing the filing frequency for enterprises.

Enterprises should, however, note an easily overlooked exception. For income from employee share awards and employee stock ownership plans (ESOPs), the organisation must withhold and pay the tax on behalf of the employee on a monthly or quarterly basis corresponding to its VAT declaration period (Point d.1, Clause 1, Article 22). Therefore, an enterprise filing VAT declarations monthly will have two parallel filing periods: quarterly PIT declarations for salaries and wages, but monthly withholding tax declarations for ESOP income. Where the organisation does not withhold and pay the tax on the individual’s behalf, such as where an ESOP is granted by an overseas parent company, the individual must directly declare tax quarterly upon transferring the shares (Point c.1.4, Clause 1, Article 22).

2. Taxpayer classification for risk-management purposes introduced for the first time.

Article 4 of Circular No. 89/2026/TT-BTC requires tax authorities to classify taxpayers by location, legal form, scale, industry, level of compliance and level of risk. Based on this classification, taxpayers are ranked for the application of priority treatment for good compliance and low risk, compliance support, or enhanced inspection, supervision and enforcement for low compliance and high risk. In particular, under Point c.4, Clause 3, Article 4, non-compliant taxpayers will be placed under focused (key-priority) tax supervision.

3. Clear allocation of responsibilities among tax authorities.

Article 5 of Circular No. 89/2026/TT-BTC distinguishes the responsibilities of the directly managing tax authority, the tax authority responsible for the locality receiving allocated tax amounts, and the tax authority managing state-budget revenues in relation to tax declaration, payment, refund, exemption and reduction, debt management and tax inspection procedures. This is particularly important for enterprises operating or maintaining dependent units in multiple provinces and subject to the allocation of tax obligations.

4. A more comprehensive framework for electronic transactions in tax administration.

Under Point a, Clause 3, Article 1, Chapter II of the Circular, comprising Articles 7 to 16, is dedicated to electronic tax transactions, including the registration and use of transaction accounts, electronic identification accounts, electronic signatures, system-incident handling and T-VAN services. Notably, under Clause 2, Article 99, the full implementation of electronic transaction methods will follow the roadmap prescribed by the tax authority pursuant to Clause 4, Article 52 of the Law on Tax Administration. In addition, under Clauses 2 and 3, Article 6, taxpayers are not required to resubmit documents already available in the Tax Administration Information System or shared through national databases, ministries or government agencies. Where sufficient data are available to determine the tax payable, the system can also support the automatic preparation of tax declarations.

5. Consolidated guidance on all tax procedures, with several notable changes.

Under Clause 3, Article 1, the Circular provides detailed guidance on tax declaration, calculation and allocation; tax payment and payment extensions; the handling of overpayments; tax refunds; tax exemptions and reductions; instalment payments; tax debt freezing; and tax debt cancellation. These matters are covered in Chapters III to VI. Compared with Circular No. 80/2021/TT-BTC, enterprises should note the following changes:

  • Automatic offsetting of tax overpayments using payment-obligation identification codes (IDs): under Article 42 of Circular No. 89/2026/TT-BTC, the Tax Administration Information System automatically matches amounts paid against outstanding and newly arising obligations by ID. Enterprises can select the obligation against which an overpayment is to be offset directly through their electronic tax transaction accounts, instead of submitting a written request as previously required.
  • Writing off overpayments outstanding for more than 10 years: under Clause 2, Article 43, an overpayment that has remained in the state budget for more than 10 years without being offset against tax obligations or claimed as a refund will be written off by the tax authority from its accounting records. Enterprises should promptly review long-outstanding overpayment balances and take action before losing the associated entitlement.
  • Automatic tax refunds and partial refund-first processing: the Circular introduces an automatic refund mechanism under which the system automatically issues the Tax Refund Decision and Refund Order (Clause 2, Article 50 and Article 51). The State Treasury must make the refund within one working day after receiving the Refund Order. Importantly, risk classification is applied to each portion of the amount claimed: only the high-risk portion is subject to inspection before refund, while the remaining portion may still be refunded first (Point c.2, Clause 1, Article 48; Point b.2, Clause 1, Article 49). As a result, the entire refund amount will no longer be withheld merely because part of the application is considered questionable. The Circular also introduces a procedure for cancelling a tax refund dossier (Clause 2, Article 47), allowing an enterprise to withdraw its refund request and carry the deductible amount forward to the next period.
  • Right to provide explanations regarding tax declaration dossiers: under Clause 7, Article 17, eligible enterprises may submit an explanatory dossier concerning their tax declaration dossier. The tax authority must notify the taxpayer whether the explanation is accepted within five working days. This taxpayer-protection mechanism was not provided under Circular No. 80/2021/TT-BTC.
  • New circumstances eligible for tax debt freezing: under Point b, Clause 1, Article 84, where an enterprise’s rights to exploit or use land or mineral resources are restricted for reasons attributable to a competent state authority, its outstanding tax may be frozen and no late-payment interest will accrue during the restriction period. This is particularly relevant to real estate and mining enterprises facing legal or procedural delays in their projects.

6. A comprehensive set of new forms and transitional provisions.

Under Point b, Clause 2, Article 1, the Circular issues standard notification forms for tax administration and tax administrative procedures, implementing Point b, Clause 2, Article 58 of Decree No. 252/2026/ND-CP. Regarding transitional arrangements, Clause 1, Article 100 provides that tax declaration dossiers for tax periods before 1 July 2026 will continue to use the previous forms. Decisions and notices issued by tax authorities before the effective date will remain valid until their stated expiry. Clause 3, Article 100 provides that overpayments arising before the effective date but not yet processed will be handled under the new Circular.

Why Is Circular No. 89 a Record 839 Pages Long?

The length of Circular No. 89 is not primarily attributable to an unusually large number of new rules. Rather, the Circular consolidates provisions and form systems previously dispersed across numerous circulars into a single instrument. It is structured into 10 Chapters, 101 Articles and 5 Appendices, as follows:

Section Provisions Key contents
Chapter I Articles 1-6 General provisions: scope of regulation, interpretation of terms, taxpayer classification, responsibilities of each tax authority, and principles for tax declaration and submission of tax dossiers
Chapter II Articles 7-16 Electronic transactions in tax administration: transaction accounts, electronic signatures, incident handling and T-VAN services
Chapter III Articles 17-34 Tax declaration, calculation and allocation by tax type: VAT, special consumption tax, corporate income tax, personal income tax, natural resources tax, environmental protection tax, land-related revenues, foreign contractor tax, foreign suppliers and e-commerce
Chapter IV Articles 35-44 Tax payment; extensions of tax payment deadlines; late-payment interest; verification of payment documents; handling of overpayments; and confirmation of the fulfilment of tax obligations
Chapter V Articles 45-64 Tax refund procedures under tax legislation and refunds of overpaid amounts
Chapter VI Articles 65-86 Tax exemptions and reductions, including under tax treaties and international agreements; instalment payments; tax debt freezing; and tax debt cancellation
Chapter VII Articles 87-90 Tax inspections at tax authority offices and taxpayer premises; online and remote inspections based on electronic data
Chapter VIII Articles 91-94 Connection and exchange of information and data between tax authorities and state agencies through the inter-agency single-window mechanism
Chapters IX-X Articles 95-101 Authorised tax collection; tax administration for national defence and security enterprises; language of dossiers; implementation provisions and transitional arrangements
Appendix I - Tax declaration dossier forms for each tax type, including declarations, allocation appendices and finalisation forms, together with lists of dossiers for supplementary declarations, explanations and extensions of tax declaration submission deadlines
Appendix II - Guidance on supplementary tax declarations in certain specific circumstances
Appendix III - Forms for electronic tax transactions, verification of payment documents, extensions of tax payment deadlines, exemption from or non-calculation of late-payment interest, handling of overpayments, tax refunds, confirmation of tax obligations, application of tax treaties and international agreements, tax exemptions and reductions, and instalment payment of tax debts
Appendix IV - Forms for notices on temporary suspension of departure, tax assessment decisions and enforcement; tax debt freezing, cancellation and reinstatement of cancelled tax debts; tax inspections; and authorised tax collection
Appendix V - Tax authority notice forms and documents sent to competent state authorities to verify information used as a basis for tax calculation and tax payment notices

The Appendices contain a very large number of forms, which account for most of the Circular’s 839 pages.

Under Clause 3, Article 99 of Circular No. 89/2026/TT-BTC, 11 tax-related circulars are repealed from 1 July 2026. Notable examples include Circular No. 80/2021/TT-BTC guiding the Law on Tax Administration and Decree No. 126/2020/ND-CP, together with its amending Circulars Nos. 94/2025/TT-BTC and 21/2026/TT-BTC; Circular No. 103/2014/TT-BTC on foreign contractor tax; Circular No. 92/2015/TT-BTC on VAT and PIT applicable to individual business operators; Circular No. 19/2021/TT-BTC on electronic transactions in taxation and its amending Circular No. 46/2024/TT-BTC; Circular No. 84/2016/TT-BTC on state-budget collection and payment procedures; Circular No. 179/2013/TT-BTC on tax debt cancellation; and Circulars Nos. 96/2016/TT-BTC and 97/2016/TT-BTC on PIT exemptions for certain specific categories of taxpayers. In addition, Clause 4, Article 99 repeals certain articles, clauses and points of seven other instruments, while Clause 5, Article 99 replaces a range of forms for household businesses and individual business operators under Circulars Nos. 18/2026/TT-BTC and 50/2026/TT-BTC with the new forms in Appendix I.

In other words, instead of consulting multiple instruments and their amendments simultaneously, from 1 July 2026 taxpayers and tax authorities need to apply a single instrument for most matters concerning the implementation of the 2025 Law on Tax Administration. These include tax registration; tax declaration, calculation and allocation; tax refunds; tax debt management; electronic transactions; the tax administration of household businesses and individual business operators; foreign contractor tax; and an extensive system of declaration forms, notices and decisions in the Appendices. The volume of these forms is also the principal reason for the Circular’s unusually high page count.

💡 Immediate Actions for Enterprises

  1. Review the PIT filing schedule: quarterly declarations for salaries and wages have applied from the second quarter of 2026 under Resolution No. 66.16/2026/NQ-CP and Official Letter No. 4021/CT-NVT. Enterprises that submitted an April 2026 monthly declaration should ensure that their second-quarter declaration includes only data for May and June to avoid duplication. From the third quarter of 2026, the new forms under Circular No. 89 must be used. Enterprises operating ESOP or employee share-award programmes should separately monitor the withholding declaration period aligned with their VAT declaration period under Point d.1, Clause 1, Article 22.
  2. Update all forms: compare the declarations and appendices currently used under Circular No. 80/2021/TT-BTC and earlier instruments against the new form system in Appendices I-IV to Circular No. 89. Dossiers relating to tax periods before 1 July 2026 will continue to use the previous forms under Clause 1, Article 100.
  3. Assess the enterprise’s “compliance profile”: the level of tax compliance and tax risk now directly determines whether an enterprise receives priority treatment or is placed under enhanced monitoring pursuant to Article 4. Enterprises should review their outstanding tax liabilities, filing history and invoice usage.
  4. Review long-outstanding tax overpayments: reconcile overpayment balances shown in the electronic tax account and arrange an offset or request a refund before balances outstanding for more than 10 years are written off under Article 43.
  5. Check the electronic tax transaction account: ensure that the account, digital signature, email address and telephone number registered with the tax authority remain valid and are updated in accordance with Chapter II of Circular No. 89.
  6. Enterprises operating in multiple locations: identify the competent tax authority for each procedure, including declaration, payment, refund, exemption and reduction, based on the allocation of responsibilities under Article 5, to avoid filing with the wrong receiving authority.

>>> Tải Thông tư 89/2026/TT-BTC

 

This newsletter has been prepared by Crowe Vietnam for general information and reference purposes only. It does not constitute legal, tax or accounting advice in relation to any specific circumstances. Laws and regulations may be amended or may no longer be in effect at the time this newsletter is accessed. Readers should consult the original legal instruments and seek advice from Crowe Vietnam’s professionals before applying the information to any particular situation. Crowe Vietnam accepts no responsibility for any loss arising from reliance on the information contained in this newsletter without obtaining appropriate professional advice.