Vietnam Tax Administration 2026: Decree 252 Compliance Guide

Effective 1 July 2026, Decree No. 252/2026/ND-CP provides the implementing framework for Vietnam’s Law on Tax Administration 2025 (Law No. 108/2025/QH15), consolidating existing tax administration regulations while introducing new compliance requirements for businesses and individual taxpayers.

The decree is complemented by two Ministry of Finance circulars:

• Circular No. 89/2026/TT-BTC, providing detailed guidance on the implementation of the Law on Tax Administration 2025 and Decree No. 252/2026/ND-CP; and
• Circular No. 90/2026/TT-BTC, governing tax registration procedures.

Together, these instruments significantly reshape Vietnam’s tax compliance framework by introducing revised tax registration and declaration procedures, new tax reporting forms, expanded electronic tax administration, additional reporting obligations, changes to filing frequencies for certain taxes, and more detailed rules governing tax payments, refunds, tax code administration, and tax enforcement.

Exit suspension rules updated for tax debtors

Decree 252 introduces clearer rules on exit suspensions for taxpayers with outstanding tax debts, including defined debt thresholds, advance notification requirements, and more flexible conditions for lifting travel restrictions. The decree also clarifies the authority of tax agencies to issue and revoke exit suspensions.

For businesses, particularly foreign-invested enterprises, the changes highlight the need to closely monitor tax compliance, as legal representatives may be subject to travel restrictions where enforcement thresholds are met.

For a detailed analysis of the new exit suspension framework, see our article: Vietnam’s New Exit Suspension Rules for Tax Debts

Standardised tax registration deadlines reduce administrative uncertainty

The decree harmonises tax registration and notification deadlines across different taxpayer categories, providing greater consistency in administrative procedures.

Where taxpayer records are connected to Vietnam’s National Population Database, changes to personal information will be synchronised automatically, reducing administrative procedures for affected taxpayers.

Relief mechanism for businesses under invoice enforcement

The decree introduces a new mechanism allowing businesses subject to invoice enforcement measures to continue issuing invoices under certain conditions.

To qualify, the taxpayer must:

• pay at least 18 per cent of the invoice’s total payment value into the state budget before the invoice is issued; and
• apply for invoices on a transaction-by-transaction basis.

Once approved, enforcement against the corresponding amount in the taxpayer’s bank account will be suspended for up to 10 working days, helping businesses maintain operations and cash flow.

Enhanced taxpayer safeguards

Decree 252 also strengthens taxpayer protections in two areas.

Protection of taxpayer information

When publishing lists of taxpayers with outstanding tax debts or tax violations, tax authorities may disclose only:

• the taxpayer’s name; and
• the final four digits of the taxpayer’s citizen identification or passport number.

The remaining identification details must be masked.

Technical system failures

Where the tax authority’s electronic systems experience technical failures or network outages:

• taxpayers may wait until the system is restored or submit documents directly or by post;
• taxpayers will not be regarded as filing late where delays result from confirmed system failures; and
• any enforcement decisions or administrative actions issued incorrectly due to technical faults must be withdrawn, cancelled or amended.

VAT refund procedures

Decree 252 and Circular 89 introduce several updates to VAT refund administration, including:

• Revised application forms and documentation requirements;
• Reduced paperwork, where information is already available through electronic invoices or tax authority systems;
• Updated procedures and processing timelines, particularly for claims subject to pre-refund inspection;
• Greater flexibility to withdraw refund applications and carry eligible VAT forward as input tax credits; and
• More standardised and digitalised procedures for VAT refund processing.

For a detailed overview of the new procedures and compliance requirements, see: Vietnam’s VAT Refund: Expanded Eligibility and Stricter Compliance Rules

Foreign e-commerce suppliers

Decree 252 introduces new tax compliance requirements for foreign suppliers conducting e-commerce and digital activities in Vietnam, including platform-based tax withholding and reporting. Where the platform assumes these obligations, foreign suppliers may not need to separately declare and pay tax on covered transactions; otherwise, they remain responsible for their own tax compliance.

The decree also introduces changes to filing frequency, transaction-level reporting, tax forms, and supporting documentation.

For a detailed analysis, see our article: Understanding Vietnam’s Tax Withholding Framework for Foreign E-Commerce Platforms

Strengthening the legal framework for profit repatriation

For the first time, Decree 252 incorporates the rules on profit remittance abroad into the tax administration framework, which were previously governed under Circular 186/2010/TT-BTC.

Notably, the Decree confirms that Global Minimum Tax (GMT) liabilities are not required to be settled as a pre-condition for profit remittance abroad, providing greater certainty for foreign investors planning dividend distributions or investment exits.

For further information on Vietnam’s profit repatriation framework, see: Profit Repatriation in Vietnam: A Brief Guide in 2026

Other enhanced tax administration and compliance

Expanded tax assessment powers

Decree 252 broadens the information sources tax authorities may use to assess tax liabilities where taxpayers fail to meet their obligations. These include data from competent authorities, official public sources, industry profit margins, and government-prescribed property valuation benchmarks. The Decree also clarifies the use of deemed or prescribed tax rates for eligible taxpayers.

Stronger information sharing and enforcement

The decree expands information sharing among tax authorities, business registration agencies, customs, banks, land authorities, and other government bodies. It also strengthens international tax cooperation through cross-border collection assistance and joint tax examinations under applicable agreements.

Businesses should therefore ensure consistency between tax filings and information submitted to other authorities, as discrepancies may be more readily identified.

Risk-based compliance measures

Compliant taxpayers may qualify for simplified procedures, faster processing, and reduced inspections under a new preferential taxpayer regime based on compliance history and risk assessment. Conversely, the tax authorities have broader powers to publicly disclose information on taxpayers involved in tax evasion, overdue tax liabilities, non-cooperation, or irregular business activities.

Five earlier decrees repealed

In addition to introducing new compliance measures, Decree No. 252/2026/ND-CP consolidates Vietnam’s tax administration framework by repealing five previous implementing decrees:

• Decree No. 126/2020/ND-CP, providing guidance on the Law on Tax Administration 2019;
• Decree No. 91/2022/ND-CP, amending Decree No. 126/2020/ND-CP;
• Decree No. 49/2025/ND-CP, concerning exit suspension thresholds for tax debtors;
• Decree No. 117/2025/ND-CP, governing tax administration for e-commerce household businesses and individuals; and
• Decree No. 373/2025/ND-CP, amending tax administration regulations.

By replacing these instruments with a single implementing decree, the Government aims to simplify the tax administration framework, reduce regulatory overlap, and align tax administration with Vietnam’s broader tax reforms that took effect on 1 July 2026.

What businesses should do next

The new Law on Tax Administration, together with Decree 252 and Circular 89, represents a significant step in the modernisation of Vietnam’s tax administration framework. By promoting greater digitalisation, enhanced data sharing, and risk-based tax administration, the new regulations are expected to increase the level of scrutiny over taxpayers’ compliance activities.

While many provisions codify existing administrative practices, the decree introduces several operational changes that businesses should review before their next compliance cycle. In particular, companies should consider:

• Reviewing internal tax governance procedures to ensure tax debts are identified and resolved before enforcement measures apply;
• Verifying that tax registration and notification processes comply with the new statutory deadlines;
• Assessing invoice management procedures in light of the new relief mechanism; and
• Ensuring finance, tax and legal teams understand the consolidated framework and the repeal of earlier implementing decrees.