On 30 June 2026, the Government issued Decree No. 252/2026/ND-CP (“Decree 252”) providing detailed guidance on a number of articles and measures for the implementation of the Law on Tax Administration No. 108/2025/QH15 (“Law 108”). Decree 252 took effect on 1 July 2026 and covers a broad range of matters, including tax registration, tax declaration and payment, tax administration procedures, e-commerce activities, international tax cooperation, preferential treatment for taxpayers, and the application of technology and data in tax administration.
Rather than introducing a separate tax regime, Decree 252 establishes detailed administrative mechanisms under the new tax administration framework. The new decree reflects the Vietnamese Government’s broader objective of creating a more transparent, data-driven, and digitally integrated tax administration system. Several provisions also provide the basis for increased use of electronic data, risk assessment and compliance management in tax administration.
Summary of Key Changes
Tax obligations and compliance
Decree 252 provides further guidance on tax registration, tax declaration, supplementary tax declarations, and tax payment deadlines. It also clarifies the circumstances in which taxpayers are exempt from submitting tax returns.
Tax registration deadlines
Some examples include:
- Organisations required to register directly with the tax authorities must generally do so within 10 working days from establishment.
- Foreign contractors registering and declaring taxes directly must register within 10 working days from signing the relevant contract.
- Individuals directly registering for a tax identification number must do so within 10 working days from the date a tax obligation arises.
- Taxpayers applying for tax refunds without an existing tax identification number must complete registration before submitting the refund application.
Businesses should also note that taxpayers registered directly with the tax authorities generally have 10 working days to notify changes to registration information. Certain personal information updates for individuals are subject to separate deadlines.
Cases exempt from tax return filing
The Decree also expands and clarifies circumstances in which tax returns are not required, including certain cases where no relevant taxable activity has arisen or where the tax authority already has sufficient information to determine the taxpayer’s obligations.
Examples include:
- Employers that have not paid salary or wage income during the year are not required to file an annual personal income tax finalisation return.
- Taxpayers are not required to submit foreign contractor tax declarations for periods where no tax has been withheld.
- Certain VAT refund applications relating to ODA-funded projects, aid programmes, and entities enjoying diplomatic privileges are exempt from separate filing requirements.
- Certain payments to foreign contractors connected with government bond investments or State lending activities may be exempt where the income falls within existing tax exemptions.
- Other situations where the tax authority can independently determine the taxpayer’s obligations based on available data.
Supplementary tax declaration dossiers
Decree 252 further provides guidance on supplementary tax declarations. In particular, where a competent authority determines that a seller has used illegal invoices or illegally used invoices, the purchaser may be required to submit a supplementary tax declaration in respect of the relevant invoices. This requirement may apply even where the relevant tax period has previously been subject to inspection or audit.
The new framework also introduces an explanatory mechanism for certain errors identified after the expiry of the five-year period for supplementary tax declarations. In such cases, the taxpayer may submit an explanatory dossier in accordance with the conditions prescribed by the Decree rather than making a supplementary tax declaration under the ordinary procedure.
Tax obligations upon exit from Vietnam
Decree 252 provides greater clarity regarding travel restrictions imposed on taxpayers with significant overdue tax liabilities.
The regulations establish clearer debt thresholds, notification procedures, and mechanisms for removing restrictions once obligations have been satisfied. The Decree also clarifies the respective responsibilities of tax authorities in initiating and lifting such measures.
For businesses, particularly foreign-invested companies, this development highlights the importance of monitoring tax liabilities and enforcement actions, as company representatives may face personal consequences where substantial unpaid tax debts remain unresolved.
Exit restrictions may apply to:
- Individual business owners and household businesses with outstanding tax debts of VND 50 million or more that remain overdue for at least 120 days.
- Legal representatives or beneficial owners of companies with overdue tax liabilities of VND 500 million or more for a period exceeding 120 days.
- Certain taxpayers that cease operating at their registered address or leave Vietnam without completing outstanding tax obligations.
Tax administration based on compliance and risk assessment
One of the most significant shifts introduced under Law 108 and Decree 252 is the move beyond traditional risk-based tax administration towards a broader compliance management model.
Under this framework, taxpayers may be assessed based on various characteristics, such as:
- Industry sector
- Legal structure
- Ownership profile
- Business scale
- Contribution to state revenue
- Historical compliance performance
Eligible taxpayers may receive preferential treatment in areas including
- automated tax administration procedures,
- processing of tax refunds and other administrative procedures,
- remote inspection and supervision,
- taxpayer support,
- access to certain procedures relating to related-party transactions, including Advance Pricing Agreements and Mutual Agreement Procedures.
The preferential treatment is subject to specific conditions. Among other requirements, taxpayers must have good compliance and low-risk ratings for at least two consecutive years preceding the year of application; establish and maintain the required electronic connection and data sharing with the Tax Administration Information System; prepare, store and transmit relevant electronic accounting, invoice and transaction data; maintain internal controls and tax risk management mechanisms; and maintain proper accounting records and financial statements in accordance with Vietnamese accounting regulations. Additional requirements apply to taxpayers with related-party transactions.
The preferential treatment is not permanent. Tax authorities may suspend or revoke it where the taxpayer no longer satisfies the prescribed conditions or where information indicates suspected tax offences. The Decree also provides for annual assessment of preferential treatment.
Digitalisation and data-driven tax administration
A central objective of Decree 252 is the modernisation of Vietnam’s tax administration system through greater use of technology, data integration, and automation.
Tax registration and many administrative procedures are expected to be conducted electronically, with some registrations potentially completed automatically through data exchange between government agencies.
The tax administration system will increasingly rely on information from multiple sources, including taxpayers, government institutions, specialised databases, international exchanges of information, and other authorised sources.
Businesses that actively share electronic data and maintain strong compliance records may benefit from streamlined administrative procedures, greater use of automated processing, and reduced direct intervention from tax authorities. While the Decree establishes the legal basis for broader use of taxpayer data, further guidance is expected regarding the practical methods through which tax authorities may access, analyse, and utilise information from taxpayers’ systems.
Tax administration for e-commerce and digital business activities
Decree 252 introduces detailed provisions governing tax registration, declaration, withholding and payment for certain overseas suppliers, non-resident individuals and businesses operating through e-commerce and digital platforms.
The provisions apply to e-commerce platforms and digital platforms with online ordering and payment functions, as well as certain organisations in Vietnam conducting digital economic activities on behalf of foreign platform operators.
The scope of entities responsible for withholding and paying tax on behalf of business individuals and household businesses operating through e-commerce platforms is also clarified and expanded. This includes platform owners, organisations or individuals authorised to manage platforms, and certain organisations in Vietnam conducting digital economic activities on behalf of foreign e-commerce platform operators.
For foreign suppliers conducting business through e-commerce platforms with online ordering and payment functions, domestic and overseas platform operators may be required to withhold, declare and pay VAT and CIT on behalf of the foreign suppliers.
Decree 252 also revises the tax filing arrangements applicable to overseas suppliers, including monthly filing or filing on each payment transaction, depending on the applicable circumstances. It further clarifies the possibility for overseas suppliers to claim benefits under an applicable double taxation agreement, subject to the relevant conditions.
Domestic e-commerce platform operators and organisations in Vietnam conducting other digital economic activities are required to register for tax and obtain a separate tax identification number for the declaration and payment of tax withheld on behalf of other taxpayers.
For platform operators subject to withholding, tax is generally declared monthly. Organisations in Vietnam making payments on behalf of other taxpayers generally declare on a transaction basis, with monthly declaration available where tax arises multiple times during a month.
Decree 252 also prescribes responsibilities for platform operators, including maintaining transaction data and supporting documents, withholding and declaring tax accurately, providing information to tax authorities when required, and handling tax previously withheld in cases involving cancelled transactions or returned goods.
International cooperation and tax transparency
Decree 252 provides for cooperation and administrative assistance between Vietnamese tax authorities and foreign tax authorities and international organisations.
The framework includes assistance in the collection of tax debts and simultaneous tax inspections under applicable multilateral agreements on administrative assistance in taxation.
The provisions support collaboration between Vietnamese tax authorities, foreign tax administrations, and international organisations in areas such as:
- Cross-border tax collection assistance
- Simultaneous tax examinations
- Exchange of tax information
- Implementation of international transparency standards
The information that may exchange includes beneficial ownership information, banking records, accounting data, Country-by-Country Reports (CbCR), financial account reporting under the Common Reporting Standard (CRS), and certain crypto-asset information where relevant.
Branches and representative offices of foreign companies in Vietnam must declare information concerning the legal owners and beneficial owners of their overseas parent companies upon tax registration and when relevant registration information changes. They must also retain supporting records for at least five years.
Strengthening requirements for profit remittance abroad
For the first time, Decree 252 directly incorporates profit remittance requirements into the tax administration framework.
While the underlying principle remains unchanged, foreign investors may only remit profits after fulfilling all applicable tax and financial obligations in Vietnam. The Decree provides additional clarity regarding the scope of those obligations, which may include taxes, state budget payments, late-payment interest, and administrative penalties. Importantly, businesses must not have any outstanding tax debts at the time profits are transferred overseas.
The Decree also clarifies requirements applicable when foreign investors terminate their investment projects in Vietnam. In such cases, tax obligations must be settled before profits are remitted, including certain obligations that may not yet have reached their statutory due date.
These provisions provide greater certainty for investors while reinforcing the tax authority’s focus on ensuring that all obligations are fully discharged before capital exits Vietnam.
Initial considerations for businesses
As Decree 252 has only recently taken effect, its practical implementation and interaction with other regulations will continue to develop. Further guidance and implementation practice may therefore be relevant to the application of certain provisions.
At this stage, businesses should consider:
- Reviewing tax registration and filing procedures;
- Assessing supplementary declaration and tax correction processes;
- Evaluating readiness for increased digital reporting and data sharing;
- Reviewing e-commerce and cross-border transaction structures;
- Confirming the accuracy of beneficial ownership information;
- Strengthening tax governance and compliance monitoring frameworks; and
- Assessing the impact of profit remittance and tax debt management requirements.
The Decree reflects Vietnam’s continued move towards a more sophisticated tax administration system built around digital technologies, integrated data, taxpayer compliance assessment, and risk-based monitoring. Businesses that proactively adapt their internal processes will be better positioned to manage compliance obligations and reduce potential tax risk.
Contact RBA Vietnam to discuss how the new regulations may affect your business and how we can support your compliance and tax planning needs.
