Decree No. 252/2026/ND-CP guiding the Law on Tax Administration 2025: key changes for enterprises from 01/7/2026

8/21/2026
Decree No. 2522026ND-CP guiding the Law on Tax Administration 2025

On 30/6/2026, the Government issued Decree No. 252/2026/ND-CP detailing and providing measures for implementation of the Law on Tax Administration No. 108/2025/QH15. The Decree takes effect from 01/7/2026, concurrently with the Law, comprises 7 Chapters and 76 Articles, and fully replaces Decree No. 126/2020/ND-CP together with four related amending and supplementing decrees (Article 74 of Decree No. 252/2026/ND-CP).

On 22/7/2026, the Tax Department issued Official Letter No. 5061/CT-CS introducing the key changes under the Decree for implementation by tax authorities and taxpayers. This newsletter summarizes the provisions highlighted in the Official Letter that directly affect enterprises and taxpayers.

1. Public disclosure of taxpayer information (Article 4)

The Decree introduces principles requiring public disclosure to be made by the proper authority and for the appropriate subjects, scope and purposes (Clauses 3 and 5, Article 4 of Decree No. 252/2026/ND-CP); disclosure through the Tax Administration Information System, together with mechanisms to update, amend or discontinue disclosure once the taxpayer has fulfilled its obligations or remedied the violation (Clauses 1 and 4); and masking or concealing certain personal identification information when information is publicly disclosed (Point a, Clause 2).

2. Tax registration (Articles 6 - 8)

Tax registration deadlines (Article 6):

  • Branches and transaction offices of credit institutions: within 10 working days from the commencement of operations (Point a.1, Clause 3), instead of from the date of licensing as previously prescribed.
  • Dependents: no later than 31/12 of the tax year (Point a.4, Clause 3), instead of within 10 working days from the date of registering for the family circumstance-based deduction.
  • Persons eligible for a tax refund but not yet having a TIN: tax registration must be completed before carrying out the tax refund procedures (Point b, Clause 3).
  • Issuance of a substitute TIN (Point c, Clause 3): within 10 working days from the date of signing a contract or business cooperation agreement; or from the date of the first payment or income payment where no contract is signed; or by the filing deadline for the first tax return where neither of the above cases applies.
  • Initial tax registration through a tax return incorporating tax registration information: by the filing deadline for the first tax return (Point d, Clause 3).
  • Individuals whose tax registration is carried out by an income-paying organization: no later than the last day of the filing deadline for the first PIT return arising from the payment of income (Point dd, Clause 3).
  • Individuals are not required to carry out procedures to amend tax registration information once the National Population Database has been connected and synchronized with the tax authority database; the system will automatically notify the individual of the updated information.

Responsibilities of taxpayers and related parties (Article 7):

  • Taxpayers must provide complete, accurate and timely tax registration information; supplement information where data from the business registration authority is incomplete; register tax for dependent units at the request of the tax authority; and legal representatives and business owners classified as tax-risk subjects must provide explanations, information and documents (Point a, Clause 1).
  • Relocation of head office to another province: after completing the procedures for changing the address, taxpayers may continue outstanding tax procedures with the tax authority at the former location (Point b, Clause 1). Previously, taxpayers had to complete their tax obligations with the former tax authority before relocating.
  • Taxpayers not operating at their registered address remain responsible for tax obligations during the period covered by the relevant notification. Owners of private enterprises, owners of single-member limited liability companies, general partners, household business owners and legal representatives must complete the tax obligations of an enterprise or household business that has been notified as inactive or had its license revoked before registering a new enterprise or household business (Points e and h, Clause 1).
  • Tax authorities shall collect and analyze information on legal representatives, business owners and related organizations and individuals for risk classification purposes (Point d, Clause 2). Authorities responsible for issuing establishment and operating licenses outside the inter-agency one-stop mechanism must share information on new issuance, amendment, temporary suspension, termination and revocation of licenses with the tax authority within 10 days (Clause 5).

3. Tax declaration (Articles 9 - 14)

Tax finalization period (Article 9): determined based on the annual accounting period under accounting regulations; PIT is determined based on the calendar year (Point dd, Clause 2).

Tax return filing deadlines (Article 10):

  • Tax declared on a transaction-by-transaction basis: the 10th day counted from the day following the date on which the tax obligation arises (Clause 1). Previously, the period was counted from the date the tax obligation arose.
  • Tax finalization returns: the last day of the third month from the end of the tax finalization period (Point a, Clause 5).
  • Individuals present in Vietnam for fewer than 183 days in a calendar year but for at least 183 days in 12 consecutive months: the deadline for the first-year tax finalization is the last day of the fourth month following the month in which the 12-consecutive-month period is completed (Point c, Clause 5). Previously, the deadline was the 90th day from the date on which the 12-consecutive-month period was completed (Point e.2, Clause 2, Article 26 of Circular No. 111/2013/TT-BTC).
  • PIT on transfers, inheritances and gifts of real estate (Clause 8): for real estate for which a Certificate has been issued, the filing deadline is the last day of the period for registering changes with the competent authority; for houses and construction works to be formed in the future, the filing deadline is the 10th day from the day following the effective date of the transfer contract or the legal document on inheritance or gift.

Cases where a tax return is not required to be filed (Article 11):

  • Organizations and individuals are still required to file PIT returns for tax-exempt income of individuals specified in Clauses 1, 2 and 17 of Article 4, Clause 19 of Article 4 relating to experts of innovative start-up projects, and Clauses 2, 3 and 4 of Article 5 of the Law on Personal Income Tax (Clause 2). Previously, individuals earning tax-exempt income were not required to file a tax return, except in cases involving real estate.
  • Individuals with additional PIT payable on salaries and wages after tax finalization of VND 50,000 or less are exempt from tax but are still required to file a tax finalization return so that the tax authority has a basis for determining eligibility for the exemption under Point a, Clause 2, Article 32 (Clause 2).
  • A tax return must be filed for tax obligations arising after submission of the dossier for TIN deactivation (Clause 5).
  • Where a Vietnamese party withholds and pays VAT and CIT on behalf of a foreign contractor that has registered for monthly tax filing, no tax return is required for a month in which no withholding arises (Clause 8). Previously, a monthly return had to be filed regardless of whether any withholding arose.
  • A tax return is not required for: organizations and individuals eligible for VAT refunds in respect of non-refundable aid or diplomatic privileges and immunities (Clause 9); cases where the tax authority calculates and notifies tax based on information obtained from the National Database or databases of state authorities, unless the taxpayer requests a tax exemption or reduction (Clause 10); and Vietnamese parties paying income to foreign organizations or individuals from investments in Government international bonds or loans to the State or Government of Vietnam where such income is not subject to VAT and is exempt from CIT (Clause 11).

Supplementary tax returns (Article 12):

  • Where an investigation authority requests that supplementary filing not be accepted, the request must clearly specify the taxpayer name, TIN, tax type, tax period and applicable period (Clause 2).
  • For periods already subject to tax inspection or examination, taxpayers may make adjustments through an explanatory dossier only for matters not addressed in the inspection or examination conclusion and provided that the adjustment does not alter the validity of any issued conclusion or decision. The taxpayer will be handled and penalized in the same manner as where the issue is identified through tax inspection or examination (Clause 4).
  • Two cases of supplementary filing pursuant to conclusions or decisions of competent authorities are provided for at Points a and b, Clause 5. In particular, a purchaser using an invoice that falls within a conclusion determining the invoice to be unlawful must make a supplementary filing even for a period that has already been inspected or examined.
  • Errors relating to input VAT shall be declared in accordance with VAT regulations (Clause 6).
  • After 5 years from the filing deadline, a supplementary tax return may no longer be submitted for errors that increase tax payable or reduce tax exempted, reduced, refunded or credited; the taxpayer may only provide an explanation to the tax authority (Clause 8). Previously, the supplementary filing period was 10 years.

Tax declaration currency and exchange rates for top-up CIT under the global anti-base erosion rules (Article 14): where the commercial bank with which the constituent entity transacts does not publish the exchange rate prescribed under Decree No. 236/2025/ND-CP, the cross exchange rate published by the State Bank of Vietnam on the nearest date preceding the tax filing date shall apply (Point a.1, Clause 3); the exchange rate applicable to supplementary tax filing is also clarified (Point a.2, Clause 3).

The Decree also amends and supplements a number of provisions on tax declaration, currency and exchange rates applicable to petroleum operations (Articles 13 and 14).

4. Tax allocation (Articles 15 and 74)

  • CIT allocation for production establishments includes processing and assembly establishments and rooftop solar power production establishments (Point b.3, Clause 2, Article 15).
  • PIT for employees working at dependent units and business locations: income-paying organizations and individuals may choose either to declare centrally at the head office and allocate tax to each unit, or to file separately with the tax authority directly managing each dependent unit or business location (Point d.1, Clause 2, Article 15). Previously, only centralized filing with allocation was available.
  • VAT is not required to be allocated for construction activities in non-tariff zones, or for consulting, surveying, design, accounting and insurance services (Point a.2, Clause 2, Article 15). Previously, this treatment was provided only through official guidance letters.
  • Allocation of VAT payable, except for computerized lottery and allocation of input VAT, shall apply only through 31/12/2026. From 2027, taxpayers will no longer be required to allocate VAT for revenues shared among different levels of the State Budget (Clause 2, Article 74).

5. Tax calculation and tax notices issued by tax authorities (Articles 16, 17 and 20)

  • Tax notice where the registration fee calculation price is not yet available, except for houses and land: no later than 5 working days from receipt of the dossier. A payment notice for cases not required to submit a tax return shall be issued on the working day following the date on which the system records sufficient information (Point b.5, Clause 2, Article 16).
  • Supplementary PIT filing for transfers, inheritances and gifts of real estate after a Certificate has been issued: the supplementary filing shall be submitted to the authority receiving the dossier under land regulations (Point a, Clause 1, Article 17), instead of the tax authority where the real estate is located.
  • The tax authority shall adjust, supplement or withdraw a tax notice where the dossier for determining financial obligations transferred by a state authority changes (Points d and dd, Clause 2, Article 20).
  • The requirement for certification by the commune-level People's Committee or a specialized authority on the non-agricultural land use tax return is abolished.

6. Tax payment where the tax authority recalculates tax (Article 21)

Where the tax authority recalculates tax due to discrepancies in data, an upward adjustment is payable within 30 days, while for a downward adjustment the payment deadline remains that stated in the initial notice (Clauses 9 and 10). Land rent for the first year is payable within 30 days from the date the land begins to be used; from the second year onward, the deadline is determined under Point a.2, Clause 3, Article 21 (Point a.3, Clause 3).

7. Withholding, declaring and paying tax on behalf (Article 22)

The Decree adds the case of sale of collateral for judgment enforcement or debt resolution (Point c, Clause 1). Organizations and individuals paying income must withhold, declare and pay PIT and VAT on behalf in respect of income earned by individuals from brokerage, insurance agency activities, lotteries and multi-level marketing, as well as business income of non-resident individuals (Point l, Clause 2). Previously, only PIT withholding was required.

8. Tax payment deadlines and extension of tax payment (Article 25)

The extension period is calculated from the date the relevant event occurs: for natural disasters, catastrophes or force majeure events, 2 years from the date of the event; for cessation of operations due to relocation at the request of a competent authority, 1 year from the date operations are required to cease (Clause 3). Previously, the extension period was calculated from the original tax payment deadline, meaning taxpayers did not receive the full extension period.

9. Late payment interest (Article 26)

Recovery of tax previously exempted or reduced: late payment interest is calculated from the date of the decision or notice granting the tax exemption or reduction to the day immediately preceding the payment date (Point b, Clause 1). Additional tax arising after tax inspection or examination: late payment interest is calculated on the additional amount payable after offsetting against overpaid tax, late payment interest and penalties; the calculation period runs from the day following the last day of the tax finalization filing deadline to the day immediately preceding the payment date (Clause 2).

10. Fulfilment of tax payment obligations (Article 27)

  • An enterprise following a change of legal form inherits all tax rights and obligations of the enterprise before conversion, including tax payable, remaining deductible input VAT and overpaid tax (Clause 2).
  • The tax authority shall notify outstanding obligations and apply collection reminders and enforcement measures against organizations and individuals inheriting tax obligations (Clause 4).
  • Remittance of profits overseas: an enterprise must have no outstanding tax debt at the time profits are remitted. Upon termination of an investment project, all obligations under the Law on Tax Administration must be fully completed, including tax amounts not yet due (Clause 6).

11. Temporary suspension of exit (Article 28)

  • A taxpayer that is not operating at its registered address will be subject to temporary suspension of exit if, after 120 days from the date the tax authority issues the notification, it has not completed procedures to reactivate or deactivate its TIN (Point c, Clause 1). Previously, the condition was the existence of overdue tax debt.
  • Authority to impose, extend or cancel a temporary suspension of exit is changed from the head of the tax administration authority to the tax administration authority itself. Where the taxpayer changes the managing authority, the new tax authority has the power to extend or cancel the suspension (Clause 2).
  • Temporary suspension of exit shall be cancelled when the outstanding tax debt falls below VND 50 million for individual business operators and household businesses, or below VND 500 million for enterprises and cooperatives. For taxpayers not operating at their registered address, cancellation applies where a dossier for TIN reactivation has been submitted, tax returns have been filed and the tax debt has been reduced below the threshold, or where the TIN has been deactivated (Point a, Clause 5). Previously, all tax payment obligations had to be fully completed.
  • The tax authority must issue the cancellation notice immediately once the conditions are satisfied, and the immigration authority shall cancel the suspension immediately upon receipt of the notice through the system (Points a and c, Clause 5). Previously, the deadline was 24 working hours.
  • Where tax has been paid but the information has not yet been updated in the system, the taxpayer shall submit a response together with a copy of the payment document through the Tax Administration Information System so that the tax authority can update the information and issue the cancellation notice (Point b, Clause 5).

12. Tax refunds (Articles 30 and 31)

The system may classify only the portion of a refund claim identified as high-risk for pre-refund inspection, while the non-risk portion is processed for refund in accordance with the regulations (Point c, Clause 1, Article 30). For dossiers subject to pre-refund inspection, the refund must be processed no later than 10 working days from the date the tax authority issues the inspection conclusion or the decision on handling violations (Point b, Clause 1, Article 31). Previously, the deadline was 40 days from receipt of a complete and valid dossier.

13. Tax exemption and reduction (Articles 32 and 33)

Household businesses and individual business operators are exempt from tax where the tax payable stated in the tax return or tax finalization return is VND 50,000 or less (Point b, Clause 2, Article 32). Dossiers for tax exemption or reduction subject to inspection at the taxpayer's premises must be processed no later than 10 working days from the date the inspection conclusion is issued (Point b, Clause 2, Article 33), instead of 40 days from receipt of a complete dossier.

14. Tax debt freezing and write-off (Articles 34 and 35)

Tax debt freezing does not apply to branches, representative offices or business locations that have ceased operations while the managing entity remains active (Clause 1, Article 34). The Decree adds tax debt freezing for taxpayers whose rights to exploit land or minerals are restricted, subject to confirmation by the competent state authority, with no late payment interest charged during the debt-freezing period (Clause 2, Article 34). The debt-freezing period is calculated from the date the tax debt freezing decision is issued (Clause 3, Article 34). The processing time for tax debt write-off dossiers is reduced to 30 days from receipt of a complete dossier (Point b, Clause 5, Article 35), instead of 60 days. Authority to write off tax debt is also granted to heads of provincial and municipal tax authorities and heads of the Large Enterprise Tax Sub-department and E-commerce Tax Sub-department (Point b, Clause 4, Article 35).

15. Tax assessment (Articles 36 and 37)

Additional bases for tax assessment include information and data provided or publicly disclosed by competent authorities (Point b, Clause 1, Article 36); profit margins (Point e, Clause 1, Article 36); and prices issued by provincial-level People's Committees and People's Councils for transfers, inheritances and gifts of real estate (Point d, Clause 1, Article 36). Under the new organizational model, tax assessment authority is vested in the Tax Department, Large Enterprise Tax Sub-department, E-commerce Tax Sub-department, provincial and municipal tax authorities, and local tax offices (Clause 1, Article 37).

16. E-commerce and digital platforms (Articles 40 - 46) - one of the most significant groups of changes

  • Foreign suppliers (Article 40): the definition now also covers operators of overseas e-commerce and digital platforms. Tax registration is not required where all Vietnam-sourced revenue has been subject to tax withholding and payment on behalf by an organization in Vietnam or by a platform operator. Tax shall be declared and paid monthly for regular business activities and on a transaction-by-transaction basis for non-regular activities. Foreign suppliers must declare information on payment-receiving accounts relating to Vietnam-sourced revenue. VAT is calculated in accordance with VAT regulations and CIT in accordance with CIT regulations.
  • Non-resident individuals conducting business on platforms without ordering and payment functions (Article 42): electronic tax transaction registration is carried out together with initial tax registration through the tax return dossier using the registered official email address (Point a, Clause 1); tax is declared on a transaction-by-transaction basis and paid electronically (Clause 2).
  • Withholding, declaring and paying tax on behalf (Article 43): operators of e-commerce platforms with online ordering and payment functions, both domestic and overseas, shall withhold and pay VAT and CIT on behalf of foreign suppliers for each transaction generating revenue in Vietnam. A business organization in Vietnam that has already withheld and paid tax on behalf must electronically notify the platform to prevent duplicate withholding. The notice must include the TIN of the withholding party, transaction or order code, transaction value, tax withheld and seller information. The parties must retain and provide supporting documents at the tax authority's request.
  • Timing and basis of withholding (Article 44): organizations in Vietnam withhold tax at the time of payment; platform operators withhold tax when a transaction is confirmed as successful and payment is accepted. Where it cannot be determined whether a transaction relates to goods or services, withholding applies at the highest percentage rate prescribed under VAT, CIT and PIT regulations (Clause 1).
  • Registration, declaration and payment on behalf (Article 45): domestic and overseas platform operators register for tax and use a TIN and electronic tax transaction account to declare and pay tax on behalf. Tax already withheld and paid on behalf in respect of cancelled transactions or returned goods may be offset. Organizations in Vietnam declare tax on a transaction-by-transaction basis and, where multiple transactions arise during a month, may choose monthly filing.
  • Responsibilities (Article 46): platform operators must manage their electronic tax transaction accounts, retain transaction data and promptly refund tax withheld and paid on behalf in respect of cancelled transactions or returned goods. Foreign suppliers must independently register, declare and pay tax on the portion of revenue not yet subject to withholding and payment on behalf.

17. Priority regime for taxpayers (Article 48) - entirely new provisions

Article 48 gives detailed effect to Article 31 of the Law on Tax Administration 2025. Priority measures include automated tax administrative procedures, shorter dossier processing times, remote inspection and monitoring, compliance support and risk warnings, and priority treatment for taxpayers with related-party transactions. Eligibility is linked to the taxpayer's level of compliance and risk, degree of electronic data connectivity and sharing, internal control system and tax risk management. Recognition, extension, suspension, revocation and re-issuance are carried out automatically through the Tax Administration Information System and are reviewed annually. Mutual recognition of authorized economic operators in the customs sector may also apply under international agreements.

18. Electronic transactions and taxpayer protection in the event of system failures (Articles 50 and 54)

The Decree introduces a new chapter, Articles 49 - 56, on technology application, data and digital transformation. Key provisions for taxpayers include: safeguarding the right to carry out tax administrative procedures for persons in special circumstances who are unable to transact electronically (Clause 1, Article 50); recognition of the legal validity of electronic dossiers and documents and the tax authority's responsibility to confirm transaction results (Clause 5, Article 50); use of electronic identity by taxpayers and the ability to transact through the National Public Service Portal, Tax Administration Information System, T-VAN service providers and payment service providers (Clauses 6 and 9, Article 50); mechanisms for handling technical incidents affecting the performance of tax obligations when systems of the tax authority or related authorities fail (Clauses 3 and 4, Article 54); and principles for handling incorrect notices or decisions issued by the system due to technical or data errors, with a view to protecting taxpayers' lawful rights and interests (Clause 6, Article 54).

19. Rights and obligations of related parties (Articles 57, 60 and 61)

  • Tax officials must provide consistent guidance on tax policies, may not impose procedures, conditions or obligations beyond those prescribed, must keep taxpayer information confidential, and may not cause inconvenience or harassment or unlawfully interfere with the determination of tax obligations (Points c, d and dd, Clause 2, Article 57).
  • Organizations and individuals that withhold, declare and pay tax on behalf must provide the tax authority with detailed information on the tax withheld and paid on behalf, together with tax payment documents, within the tax payment deadline (Clause 2, Article 60), facilitating taxpayers' PIT finalization and refund procedures.
  • Banks, payment service providers and payment intermediaries must additionally provide information on the branch where a taxpayer's account is opened (Point a.1, Clause 7, Article 61); pay interest where tax amounts are transferred late, incompletely or recorded late in the State Budget (Point a.3, Clause 1, Article 61); may not cancel a money transfer order or refund tax already paid once the information has reached the Tax Administration Information System and the tax authority has offset the taxpayer's debt (Point b.2, Clause 1, Article 61); and must transmit electronic tax payment documents to the tax authority in real time (Point b, Clause 2, Article 61).

20. Tax debt enforcement (Articles 65 - 73)

  • General provisions (Article 65): enforcement measures are not applied to organizations with tax debt below VND 3 million or to household businesses and individuals with tax debt below VND 1 million, except where the taxpayer is not operating at its registered address (Point b, Clause 3). An enforcement decision takes effect from the date of signing and ceases once the enforced debt has been fully paid (Points c and d, Clause 4), replacing the previous 30-day or one-year validity periods. Deputies may be authorized to issue enforcement decisions (Point b, Clause 6).
  • Deduction of funds and freezing of accounts (Article 66): additional accounts are excluded from enforcement, including accounts receiving apartment building maintenance funds, accounts serving as collateral for non-performing loans, and petroleum price stabilization fund accounts (Clause 2). The tax authority may issue an additional enforcement decision for newly identified accounts (Point c, Clause 4). A single decision may provide for both account freezing and deduction of funds; the credit institution must immediately freeze the account, report the balance and transfer funds on the same day or the next working day in accordance with the collection order, with the entire process conducted electronically (Clause 5).
  • Salary deductions (Article 67): enforcement by deduction no longer applies to persons receiving pensions or loss-of-working-capacity allowances. It applies to employees with employment contracts of 3 months or more, instead of 6 months as previously prescribed (Point b, Clause 1).
  • Suspension of invoice use (Article 69): a taxpayer subject to invoice enforcement that wishes to use invoices on a transaction-by-transaction basis must pay 18% of the total payment value stated on the invoice. The taxpayer may also register one account with the tax authority for temporary suspension of fund deduction and account-freezing enforcement for up to 10 working days, with the amount suspended corresponding to the total payment value of the invoice used (Clause 4). The provision also clarifies enforcement at the head office where enforcement cannot be implemented at a branch or business location (Clause 6).
  • Third parties (Article 70): this measure may be applied immediately once the tax authority has sufficient grounds to determine that a third party owes a debt to, or holds money or assets of, the taxpayer (Clause 1), without waiting for prior enforcement measures. A third party that fails to pay on behalf or transfer the assets is subject to administrative penalties (Point c, Clause 5). Non-cash assets or matured receivables are handled through distraint and auction procedures (Point b, Clause 4).
  • Distraint and auction of assets (Article 71): the measure may be applied immediately where sufficient grounds and lawful information on the assets are available (Clause 1). The tax authority conducts verification, while commune-level and provincial-level People's Committees organize the distraint and auction (Clauses 4 and 5). Proceeds are used first to pay enforcement costs before outstanding tax debt (Point b, Clause 7).
  • Request to initiate bankruptcy proceedings (Article 72) - new measure: applies to enterprises and cooperatives that have not operated at their registered address for more than 3 years from the date of notification without reactivating or deactivating their TIN, or that have been subject to enforcement for 3 years or more without successful debt recovery.
  • Revocation of licenses (Clause 1, Article 73): applies where enforcement has been in place for 3 years or more without successful debt recovery, except for enterprises and cooperatives that have filed for bankruptcy; to foreign organizations and individuals registered to conduct business on e-commerce platforms in Vietnam; and where a court returns a bankruptcy petition or refuses to open bankruptcy proceedings.

21. Effectiveness and omitted provisions (Articles 74 and 75)

From 01/7/2026, the Decree fully replaces Decree Nos. 126/2020/ND-CP, 91/2022/ND-CP, 373/2025/ND-CP, 49/2025/ND-CP and 117/2025/ND-CP (Article 74). The Decree also omits 10 groups of provisions, notably for enterprises and individuals: all provisions on presumptive tax, implementing the policy to abolish presumptive tax under Resolution No. 68-NQ/TW; all provisions on business license fees, which ceased to be collected from 01/01/2026 under Resolution No. 198/2025/QH15; the exemption from filing PIT finalization returns where additional tax payable is VND 50,000 or less; separate tax withholding documents for e-commerce activities; enforcement through deductions from pensions and loss-of-working-capacity allowances; and provisions on water surface rent.

💡 Recommendations for enterprises

  1. Review the compliance calendar: tax finalization deadlines are determined based on the annual accounting period; filing deadlines for transaction-by-transaction declarations are counted from the day following the date the obligation arises; and deadlines for registration of substitute TINs vary depending on the relevant case.
  2. Review prior tax periods: the period for supplementary filing has now been reduced to 5 years. Priority should be given to reviewing the 2021-2022 periods before the relevant deadlines expire.
  3. FDI enterprises: confirm that there is no outstanding tax debt before each remittance of profits overseas; when terminating an investment project, complete all tax obligations, including amounts not yet due.
  4. Enterprises with dependent units or business locations in other provinces: consider the PIT filing method, either centralized filing with allocation or separate filing, and prepare for the discontinuation of VAT allocation from 2027.
  5. E-commerce platforms, digital platforms and organizations making payments to foreign suppliers: update withholding procedures and electronic notification mechanisms to avoid duplicate withholding, and retain complete supporting documents.
  6. Legal representatives and business owners: monitor the tax debt thresholds of VND 500 million for enterprises and VND 50 million for household businesses and individual business operators, together with the electronic response mechanism where tax has been paid but the system has not yet been updated, to avoid temporary suspension of exit.

>>> Download Decree 252/2026/ND-CP

>>> Official Dispatch 5061/CT-CS

 

This newsletter has been prepared by Crowe Vietnam for general information purposes only and does not replace professional advice for any specific case. Enterprises should refer to the original legal documents and consult professional advisers before applying the information to specific circumstances.