Vietnam's Decree No. 252/2026/NĐ-CP, effective 1 July 2026, establishes detailed rules for implementing the Law on Tax Management, introducing new provisions on taxpayer compliance, e-commerce taxation, enforcement measures, international cooperation and a priority regime for low-risk taxpayers.
Vietnam issued Decree No. 252/2026/NĐ-CP on 30 June 2026, providing detailed regulations and measures for implementing the Law on Tax Management. The decree applies to taxpayers, tax administration authorities, tax officials, and other state agencies, organisations and individuals involved in tax administration.
Public disclosure and tax administration
Under the decree, tax authorities must publicly disclose information on taxpayers that violate tax laws. This includes taxpayers involved in tax evasion, those with tax debts outstanding for more than 90 days, and individuals who have not fulfilled their tax obligations before leaving Vietnam.
The state budget will prioritise funding for tax administration, including the development and operation of information technology systems, digital transformation initiatives and e-invoicing infrastructure.
Priority regime for compliant taxpayers
A priority regime has been introduced for taxpayers that maintain high compliance ratings and low-risk profiles for at least two consecutive years.
Eligible taxpayers will benefit from automated administrative procedures, shorter processing times for tax refund and exemption applications, and exemption from planned inspections at their headquarters unless indicators of high tax risk are identified.
International tax cooperation
The decree establishes procedures for cooperation with foreign tax authorities, including simultaneous tax audits and the exchange of tax information under international treaties to support transparency and tax administration.
Tax registration and filing obligations
Taxpayers must obtain a Tax Identification Number (TIN) within prescribed deadlines, including within 10 working days of receiving a business registration licence or commencing operations. The TIN must be used on invoices, contracts and payment accounts maintained with credit institutions or foreign bank branches.
The decree also confirms filing deadlines for tax declarations:
- Monthly returns: No later than the 20th day of the following month.
- Quarterly returns: No later than the last day of the first month of the following quarter.
- Annual tax finalisation: No later than the last day of the third month following the end of the calendar or fiscal year.
Businesses making quarterly provisional Corporate Income Tax (CIT) payments must ensure that payments made during the four quarters amount to at least 80% of their total annual CIT liability.
E-commerce and digital platform measures
The decree introduces specific tax administration requirements for digital business activities.
Foreign providers without a permanent establishment in Vietnam that generate income from e-commerce or digital services must register, declare and pay taxes directly or through authorised representatives.
Operators of e-commerce platforms are required to withhold, declare and pay taxes on behalf of household and individual sellers using their platforms. Banks and payment service providers must also provide transaction data to tax authorities to support the administration of cross-border digital services.
Tax assessment powers
The decree authorises tax authorities to conduct Tax Assessment (Ấn định thuế) where taxpayers fail to register, submit tax returns or maintain accurate accounting records.
Tax assessments may be based on comparisons of revenue and profit margins with at least three similar businesses operating in the same industry or locality.
Enforcement measures
The decree expands enforcement measures available to tax authorities where tax liabilities remain unpaid.
These measures include freezing and recovering funds from bank accounts, deducting between 10% and 30% of salaries or income, suspending customs procedures for imported and exported goods, stopping the use of e-invoices, seizing assets for public auction, and revoking business registration certificates or operating licences.
Business owners or legal representatives with tax debts exceeding 500 million VND, or individuals with tax debts exceeding 50 million VND, may also be temporarily prohibited from leaving Vietnam.
Late payment interest
Late tax payments remain subject to an interest charge of 0.03% per day on the overdue amount.
However, the decree provides that late payment interest will not apply in certain circumstances, including where taxpayers are awaiting payment from the state budget for goods or services supplied.
The decree came into effect on 1 July 2026.
