Vietnam’s Tax and Accounting Updates for Businesses in 2026

Recent regulatory updates on Vietnam’s tax and accounting affect multinational and foreign firms, requiring companies to assess risks and prepare for implementation on time.

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Vietnam has recently introduced a series of regulatory updates on tax and accounting management, directly impacting compliance for multinational enterprises and foreign-invested firms. The main changes involve the Global Minimum Tax (GMT), Corporate Income Tax (CIT), and enterprise accounting standards.

Companies operating in Vietnam should evaluate their risks and prepare to implement these changes in accordance with the relevant timelines. 

GMT implementation in Vietnam 

Legal basis and timing 

Vietnam issued Decree No. 236/2025/ND-CP on 29 August 2025, providing detailed guidance on the implementation of the GMT in accordance with the OECD Pillar Two framework. The decree took effect on 15 October 2025 and applies from the 2024 fiscal year onward. 

In-scope taxpayers 

Multinational enterprises (MNEs) with consolidated revenue of at least EUR 750 million (US$875 million) in at least two of the four years prior to the testing year are considered in-scope MNEs; and

Vietnam-located entities of the in-scope MNEs, including:

• Constituent entities (CEs), except for stateless CEs;
• Joint ventures and subsidiaries of joint ventures (“JVs and JV subsidiaries”); and
• Permanent establishment (PEs), except for stateless PEs.

Compliance obligations in Vietnam 

If a Vietnam entity is a subsidiary of a qualifying foreign MNE group

Accordingly, MNE groups must notify the appointment of the Filing CE and provide the list of in-scope CEs to the Vietnamese tax authority using Form No. 01/TB-DVHT. The appointed Filing CE must then complete tax registration to obtain a 10-digit tax code for tax declaration and payment purposes. GMT filing requirements 

All GMT-related filings must be submitted electronically via the General Department of Taxation’s online portal. 

CIT updates 

Legal basis and timing 

CIT compliance requirements were updated under Decree No. 320/2025/ND-CP, effective from 15 December 2025 and applicable from the 2025 tax period onward. 

Capital transfer taxation 

The decree introduces a fundamental change to the taxation of capital transfers by foreign investors: 

• Income derived from direct or indirect capital transfers by foreign enterprises, regardless of the existence of a permanent establishment in Vietnam, shall be subject to CIT in Vietnam, except where such transfers are intra-group ownership restructurings that do not result in a change to the ultimate parent company of the entities that directly or indirectly hold ownership interests in a Vietnam-based enterprise and no taxable income is generated.
• The previous 20 percent CIT on net capital gains is replaced by a deemed tax rate of 2 percent on gross transfer proceeds. 

• The rule applies to transfers of capital contributions in limited liability companies and sales of shares in non-public joint-stock companies. 

These changes may significantly affect transaction pricing, withholding exposure, and tax modeling for both direct and indirect transfers. 

For more details, please see: Capital Transfer Taxation and Exclusions Under Decree 320: A Practical Guide

Deductibility of expenses and non-cash payment threshold 

The threshold for requiring non-cash payment documentation has been reduced: 

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• Expenses with a value of VND 5 million or more per transaction are deductible for CIT purposes only if supported by non-cash payment evidence. 

• This replaces the previous VND 20 million threshold and expands the scope of transactions subject to enhanced documentation requirements. 

New accounting regulations under Circular 99 

Legal basis and timing 

The Ministry of Finance issued Circular No. 99/2025/TT-BTC on 27 October 2025. The circular takes effect from January 1, 2026, and applies to financial years beginning on or after that date, replacing the prior accounting framework under Circular No. 200/2014/TT-BTC. 

Flexible chart of accounts 

Circular 99 allows enterprises greater flexibility in designing and updating their chart of accounts to reflect business operations and group consolidation requirements. Companies are expected to formalize changes through internal accounting policies or equivalent documentation. 

ERP alignment considerations 

The introduction of a flexible chart of accounts presents an opportunity for companies to align Vietnam subsidiaries with group ERP systems. Potential implications include: 

• Shorter consolidation timelines 

• Parallel reporting under Vietnamese Accounting Standards and group systems 

• Improved centralized financial control and reporting consistency 

Practical considerations for businesses 

Companies affected by one or more of the above developments should consider: 

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Enhancing internal audit and risk management

• Conducting a GMT scoping assessment at group and local entity level;

• Reviewing transaction structures and payment practices in light of updated CIT rules; and

• Updating accounting policies and system configurations ahead of Circular 99 implementation.

These proactive measures could help prevent unwanted tax exposures, compliance gaps, and late-stage system adjustments, while enabling companies to manage implementation risks better, maintain reporting consistency, and respond efficiently to increased scrutiny under Vietnam’s evolving tax and accounting management framework. 

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