Circular No. 90/2026/TT-BTC of the Minister of Finance, issued on 30/6/2026 and effective from 01/7/2026, replaces Circular No. 86/2024/TT-BTC. In addition to adding 3 new cases required to register directly with the tax authority under Clause 2, Article 4, all relating to e-commerce, the digital economy, and the Global Minimum Tax, the Circular clearly specifies 2 cases not required to register for tax and simplifies dependent registration procedures when taxpayers change workplaces.
Under Point e, Clause 2, Article 4, a non-resident individual conducting business on an e-commerce platform without online ordering and payment functions, as prescribed in Article 42 of Decree No. 252/2026/ND-CP, must register directly with the tax authority.
The key point is that the obligation is determined by the platform model, rather than applying to every non-resident individual:
This is a new provision. Circular No. 86/2024/TT-BTC contained only general rules for foreign suppliers and non-resident foreign individuals engaged in e-commerce, without separately categorizing non-resident individuals by platform model. Circular No. 90/2026/TT-BTC also excludes this group from the scope of "foreign contractors and foreign subcontractors" under Point g, Clause 2, Article 4, thereby avoiding overlapping classifications.
Under Point h.3, Clause 2, Article 4, operators of domestic e-commerce platforms and other digital platforms with online ordering and payment functions, as prescribed in Article 43 of Decree No. 252/2026/ND-CP, shall withhold and remit tax on behalf of:
Tax identification number: Under Point e, Clause 2, Article 5, entities withholding and remitting tax on behalf under Point h, Clause 2, Article 4 are issued a 10-digit TIN referred to as a "substitute TIN", separately for each category of taxpayer for which tax is withheld and remitted. When the taxpayer changes information, temporarily suspends operations, deactivates, or reactivates its primary TIN, the tax authority automatically updates the substitute TIN accordingly; the taxpayer is not required to submit dossiers under Chapters II and III for this substitute TIN.
Comparison with the previous rules: the obligation of e-commerce platforms with payment functions to withhold, declare, and remit tax on behalf was introduced under Decree No. 117/2025/ND-CP (effective from 01/7/2025) and is now inherited and expanded under Articles 43 and 44 of Decree No. 252/2026/ND-CP. Therefore, the new feature of Circular No. 90/2026/TT-BTC is the tax registration procedure and the separate substitute TIN issued to the platform operator, rather than the withholding obligation itself. Under Circular No. 86/2024/TT-BTC, substitute TINs were mainly issued to organizations withholding for foreign contractors, foreign suppliers, and business cooperation parties; platform operators were not included.
Under Point o, Clause 2, Article 4, an organization declaring and paying top-up corporate income tax under the Global Minimum Tax rules must register directly with the tax authority.
Under Point i, Clause 2, Article 5, the organization is issued a 10-digit TIN to directly declare and pay top-up corporate income tax. Tax registration is carried out in accordance with Article 15 of Decree No. 236/2025/ND-CP (detailing Resolution No. 107/2023/QH15 on the Global Minimum Tax) and Circular No. 90/2026/TT-BTC.
This requirement was not previously addressed in Circular No. 86/2024/TT-BTC.
Alongside the expanded scope, Circular No. 90/2026/TT-BTC clearly specifies two cases in which tax registration procedures are not required:
Another notable change concerns procedures for updating tax registration information. Under Point đ, Clause 4, Article 23 of Circular No. 90/2026/TT-BTC:
"A taxpayer is required to register and submit supporting documents for each dependent only once throughout the period in which the family circumstance-based deduction is claimed. Where a taxpayer changes workplaces, the taxpayer must provide the new income-paying organization with supporting documents for the dependent in accordance with personal income tax law in order to claim the family circumstance-based deduction."
Accordingly, from 01/7/2026, an employee changing workplaces only needs to provide the new income-paying organization with the dependent's supporting documents and is not required to re-register the dependent.
Under the previous rule at Point i, Clause 1, Article 9 of Circular No. 111/2013/TT-BTC, a taxpayer changing their workplace or place of business was required to "register and submit supporting documents for dependents in the same manner as an initial dependent registration". This procedural reform directly affects employees and enterprises' HR and payroll functions. From 01/7/2026, supporting documents for dependents shall comply with Article 4 of Circular No. 87/2026/TT-BTC.