Decree 252/2026/ND-CP on tax administration

Full title: Decree detailing certain articles of, and measures to implement, the Law on Tax Administration, No. 252/2026/ND-CP
Issued by: the Government on the proposal of the Minister of Finance, 30 June 2026 (signed by Deputy Prime Minister Nguyen Van Thang)
In force from: 1 July 2026 (Clause 1, Article 74)
Structure: 7 chapters and 76 articles, with no appendix; the forms are issued by the Ministry of Finance (Point b, Clause 2, Article 58)
Replaces: Decree 126/2020/ND-CP; Decree 91/2022/ND-CP; Decree 49/2025/ND-CP on exit ban thresholds; Decree 117/2025/ND-CP on tax administration for household and individual sellers on e-commerce platforms; Decree 373/2025/ND-CP (Clause 3, Article 74)
Still in force: Decree 125/2020/ND-CP on administrative penalties for tax and invoice violations (as amended by Decree 102/2021/ND-CP, Decree 310/2025/ND-CP and Decree 291/2026/ND-CP; consolidated text 27/2026/VBHN-ND-BTC), until it is replaced (Clause 4, Article 74)
Legal basis: the Law on Government Organisation No. 63/2025/QH15 and the Law on Tax Administration No. 108/2025/QH15 (passed on 10 December 2025, in force from 1 July 2026 under Clause 1, Article 52 of the Law)
Official Vietnamese text: Official Gazette portal · Official Gazette No. 401, 16 July 2026

Note: this page is LexData’s own unofficial English summary of the main rules. It is not the full text of the Decree or an official translation. The parts on oil and gas, land charges, imports and exports, household businesses and the duties of State bodies are not covered. Only the Vietnamese text has legal effect.

Scope and structure

The Decree details the points that the Law on Tax Administration No. 108/2025/QH15 leaves to the Government and sets measures to implement the Law (Article 1). Files, forms and many procedural steps are still left to the Minister of Finance.

Chapter	Subject	Articles
I	General rules, public disclosure of taxpayer information	1–5
II	Tax registration; tax returns; quarterly payments, payment deadlines, late payment interest, exit bans; refunds, exemptions and reductions; debt suspension and write-off; tax assessment	6–39
III	Tax returns and payments for business on e-commerce platforms	40–46
IV	International cooperation, the priority regime, technology and data	47–56
V	Duties of the parties; information supply and exchange; tax procedure services	57–64
VI	Enforcement of administrative decisions on tax	65–73
VII	Entry into force, transition, implementation	74–76

When the last day of a deadline to file, to pay or for the authority to decide falls on a day off, the deadline moves to the next working day (Clause 7, Article 3).

Tax registration (Articles 6 and 7)

Tax registration is done electronically or automatically. Where the tax authority receives the data from the business registration office under the one-stop mechanism, the taxpayer does not register separately (Clause 1, Article 6).
For companies under the one-stop mechanism, the tax registration deadline is the enterprise registration deadline, including for branches and business locations (Clause 2, Article 6), under Decree 168/2025/ND-CP.
Taxpayers that register directly with the tax authority have 10 working days from the date of the establishment and operation licence, the start of business, or the date of signing the contract for foreign contractors that pay tax directly (Point a, Clause 3, Article 6). Changes must also be reported within 10 working days (Point e.1, Clause 3, Article 6).
For a complete file, the tax authority confirms acceptance within 3 working days; for an incomplete file, it notifies the taxpayer within 2 working days (Points a and b, Clause 2, Article 7).
If a move of the head office to another province changes the tax authority in charge, the company must file all returns already due and pay all tax at the old tax office. Uncredited input VAT is carried over to the new office (Point b, Clause 1, Article 7).

Temporary suspension of business (Articles 6 and 7)

A suspension notice is part of tax registration (Clause 1, Article 10 of the Law). For companies under the one-stop mechanism, the deadline is the enterprise registration deadline (Clause 2, Article 6), and the filing is made with the business registration office under Decree 168/2025/ND-CP. See temporary business suspension in Vietnam.
Direct registrants notify the tax authority at least 1 working day before suspending, and each notice may cover up to 12 months. Resuming on the scheduled date needs no notice; resuming early needs a notice at least 1 working day before (Points g.2 to g.4, Clause 3, Article 6).
During the suspension (Point c, Clause 1, Article 7):
- no tax returns are due, unless the suspension does not cover a full month, quarter or year;
- invoices may not be used; if the tax authority allows invoice use, returns must be filed;
- decisions on debt collection, enforcement, exit bans, audits and penalties still apply.

Taxpayers not operating at the registered address

Once the tax authority gives notice that a company is not operating at its registered address:

The tax code may only be used to close or restore it (Clause 5, Article 8). The company may not suspend business until the tax code is restored (Point e.2, Clause 1, Article 7).
To restore it, the company must file all missing returns and pay the tax due, unless its legal status has been restored or payment by instalments has been accepted under Clause 6, Article 48 of the Law (Point dd, Clause 1, Article 7).
The tax authority may publish the full name and the last 4 characters of the identity card or passport number of the owner and the legal representative (Point a, Clause 2, Article 4).
These individuals must settle the company’s tax obligations before registering tax for a new company that they represent or manage (Point h, Clause 1, Article 7).
After 120 days without restoring or closing the tax code, the legal representative and the beneficial owner may face an exit ban (Point c, Clause 1, Article 28).
After 3 years, if enforcement has failed, the tax authority may petition for bankruptcy (Point a, Clause 1, Article 72).

Closing the tax code and dissolution

Companies under the one-stop mechanism register dissolution with the business registration office after completing their tax payment obligations (Clause 2, Article 6). Direct registrants file to close the tax code within 10 working days of the document ending operations (Point h, Clause 3, Article 6).
The company must complete its returns and payments and settle overpayments and uncredited VAT, including those of its dependent units. Dependent units close their tax codes before the parent (Point d, Clause 1, Article 7).
The finalisation return on dissolution, termination, division, separation, merger or consolidation is due by the 45th day after the decision (Point b, Clause 5, Article 10).
After a suspension, dissolution or bankruptcy, the legal representative must keep the accounting records in Vietnam and tell the tax authority where they are kept (Clause 5, Article 63).

Filing deadlines (Articles 9–11)

The finalisation period follows the annual accounting period; for personal income tax (PIT) it is the calendar year (Point dd, Clause 2, Article 9).

Return	Deadline	Source
Per transaction	10th day after the day the obligation arises	Clause 1, Art. 10
Monthly	20th day of the following month	Clause 2, Art. 10
Quarterly	Last day of the first month of the following quarter	Clause 3, Art. 10
Annual	Last day of the first month of the following calendar or fiscal year	Clause 4, Art. 10
Annual finalisation	Last day of the 3rd month after the end of the finalisation period	Point a, Clause 5, Art. 10
Individuals finalising PIT on employment income themselves	Last day of the 4th month after the calendar year ends	Point c, Clause 5, Art. 10
Resident foreigners ending a labour contract	Before leaving Vietnam, and no later than 45 days after the contract ends	Point d, Clause 5, Art. 10

The payment deadline for self-assessed tax is the last day of the filing deadline. That rule is in Point a, Clause 1, Article 14 of the Law (Clause 1, Article 25). The country-by-country report follows the decree on related-party transactions (Clause 7, Article 10).
No return is required (Article 11) from: an export processing enterprise with only export processing activities, for VAT (Clause 3); a taxpayer during a suspension (Clause 4); an income payer with no PIT withheld in the month or quarter, except the last period of the year or the period of dissolution or reorganisation where no finalisation is due (Clause 6); a Vietnamese party filing foreign contractor tax monthly with no withholding in that month (Clause 8).

Supplementary returns and tax allocation (Articles 12 and 15)

The 5-year limit for supplementary returns is set by Clause 5, Article 12 of the Law. After that, only an explanation may be submitted (Clause 8, Article 12).
An increase in the VAT refund claimed may only be declared before the refund claim is filed (Point a, Clause 6, Article 12).
Where a competent authority concludes that a seller used invoices unlawfully, the buyer must file a supplementary return, even for periods already audited (Point b, Clause 5, Article 12).
Companies with dependent units or business locations in another province must allocate some taxes to that province (Article 15). VAT allocation under Points a.2 to a.6, Clause 2, Article 15, such as for construction contracts worth VND 1 billion or more or dependent production facilities, applies only until 31 December 2026 (Clause 2, Article 74).

Quarterly CIT, extensions and late payment interest (Articles 24–26)

Corporate income tax (CIT) is paid provisionally each quarter, by the last day of the first month of the next quarter. The four payments must total at least 80% of the tax on annual finalisation; interest on any shortfall runs from the day after the Q4 deadline (Article 24).
Payment extensions run for up to 2 years after losses from force majeure, and 1 year where the business must stop to relocate at the request of a competent authority (Clause 3, Article 25).
The late payment interest rate of 0.03% per day is set by Point a, Clause 2, Article 16 of the Law. The Decree sets how the period is counted (Clause 1, Article 26).
No late payment interest is charged where a supplier has not yet been paid for goods or services funded by the State budget, up to the unpaid amount. The relief does not cover PIT or foreign contractor tax that must be withheld (Point a, Clause 3, Article 26).

Profit remittance abroad (Clause 6, Article 27)

Each year, at the end of the fiscal year, a foreign investor may remit profits once the invested company has filed its audited financial statements and CIT finalisation return and paid the tax due. At the time of remittance, the company must have no outstanding tax debt (Point a).
On ending the direct investment, all obligations must be met, including those not yet due (Point b).
Profits of a year may not be remitted if that year’s financial statements still show accumulated losses after loss carry-forward (Point c).

Exit bans (Article 28)

Who	Condition	Source
Individual traders and heads of household businesses	Subject to enforcement, tax debt of VND 50 million or more, overdue 120 days or more	Point a, Clause 1
The beneficial owner and the legal representative of a company	Company subject to enforcement, tax debt of VND 500 million or more, overdue 120 days or more	Point b, Clause 1
The same individuals	Company not operating at its registered address, and 120 days later the tax code has not been restored or closed	Point c, Clause 1
Foreign individuals	Overdue tax debt; no threshold is stated	Point d, Clause 1

Beneficial owners are identified under the Law on Enterprises. In the cases in Points a, b and c, the tax authority gives 30 days’ notice in the taxpayer’s e-tax account (Point a.1, Clause 3). The ban is lifted as soon as the remaining debt falls below the threshold, when the tax code is restored or closed (Point c cases), or when a foreign individual has paid in full (Clause 5).

Refunds, exemptions and reductions (Articles 29–33)

Audit before refund applies to: a first refund claim for each investment project or refund case; claims within 2 years after a penalty for tax evasion; high-risk claims; and refunds on dissolution or bankruptcy (Clause 1, Article 30). Other claims are refunded first (Clause 3, Article 30).
Acceptance of a refund file: 3 working days. Decision: 6 working days (refund first) or 10 working days after the conclusion of an on-site audit (audit first), not counting time spent on explanations (Article 31).
Exemptions and reductions assessed by the tax authority are decided within 30 working days after acceptance (Point a, Clause 2, Article 33).

Tax assessment (Articles 36–38)

Tax may be assessed using the tax authority’s data, commercial databases and a comparison with 3 businesses in the same line and of the same size (Clause 1, Article 36). Assessment is allowed where a company fails to meet the transfer pricing rules (Point a.6, Clause 2, Article 36). A taxpayer who disagrees must still pay, and may complain or sue (Clause 1, Article 38).

E-commerce and foreign suppliers (Articles 40–46)

Foreign suppliers earning revenue in Vietnam through digital platforms register directly, declare the accounts they use to receive payments, and file and pay monthly if they do business regularly (Clauses 1 and 2, Article 40). A transaction arises in Vietnam based on 2 non-conflicting data points: payment data plus residence or access data such as the IP address (Point c, Clause 2, Article 40).
Vietnamese companies using the VAT credit method that buy from foreign suppliers or non-resident individuals on e-commerce platforms must withhold and pay the seller’s VAT (on services), CIT and PIT (Clause 3, Article 43). Tax is withheld at the time of payment; if the type of goods or service cannot be identified, the highest rate applies (Article 44). The withheld tax is declared per transaction, or monthly if there are several in the month (Clause 3, Article 45).
Platform operators with ordering and payment functions withhold and pay tax for household and individual sellers and for foreign suppliers (Article 43).

Priority regime (Article 48)

Taxpayers with a good compliance rating and low risk for at least 2 consecutive years, electronic data sharing with the tax authority, internal controls and financial statements under Vietnamese Accounting Standards (Clause 3) receive automatic approvals, shorter processing times, refund first and audit later, remote audits, and no inclusion in on-site audit plans unless there are signs of high risk (Clauses 1 and 2). Recognition is automatic, with an annual review (Clauses 4 and 5).

Public disclosure of taxpayer information (Article 4)

The tax authorities publish the tax code, name, address and reason (Point a, Clause 2) for taxpayers that:

evade tax or persistently fail to pay, or have debts more than 90 days overdue. This group is published automatically each month (Point c, Clause 3);
refuse to provide information, fail to comply with an audit decision, or fail to explain invoice risks flagged by the system; the system automatically alerts the buyers (Point b.1, Clause 2);
are not operating at the registered address, have ceased operating without closing the tax code, or are temporarily suspended (Clause 1).

Once the obligation is met, the system updates the status automatically (Clause 4).

Information supply and exchange (Articles 60 and 63)

Business partners, customers and auditors must provide information on a taxpayer on the tax authority’s written request, within 10 working days (Clauses 3, 4 and 8, Article 60).
International exchange covers exchange on request (beneficial owners, bank and accounting data) and automatic exchange (country-by-country reports, financial accounts, crypto-asset reports). Taxpayers may not refuse on grounds of bank secrecy (Clause 2 and Point b, Clause 3, Article 63).
Branches and representative offices of foreign companies must declare and update the legal owners and beneficial owners of the foreign parent at first tax registration and on any change, and keep the records for at least 5 years (Clause 4, Article 63).

Enforcement (Articles 65–73)

Enforcement is not yet applied to debts of up to VND 3 million (organisations) or VND 1 million (individuals), except for taxpayers not operating at their registered address (Point b, Clause 3, Article 65).

Measure	When	Source
Debiting or freezing bank accounts	After the 90th day from the payment deadline, after an extension ends, or on asset dispersal or not operating at the registered address	Point a, Clause 4, Art. 66
Deducting 10% to 30% of salary (individuals)	30 days after an account enforcement decision without full recovery	Clauses 1 and 4, Art. 67
Stopping invoice use	Account enforcement is not possible, or 30 days have passed without full recovery. To issue invoices one by one, the taxpayer must first pay at least 18% of the payment value on the invoice	Clauses 1 and 4, Art. 69
Collecting from third parties	A party holding the taxpayer’s money pays it over within 15 days	Point a, Clause 4, Art. 70
Bankruptcy petition (companies and cooperatives)	Enforcement for 3 years or more has not recovered the debt	Clause 1, Art. 72
Revoking registration certificates and licences	Other taxpayers under enforcement for 3 years or more without recovery; the court returns the petition or does not open bankruptcy proceedings	Clause 1, Art. 73

As an employer, a company that receives a salary deduction decision for an employee must deduct from the next pay period, and must tell the tax authority within 5 working days if the labour contract ends (Clause 5, Article 67). Once it receives the tax authority’s written request, a company that owes money to a taxpayer under enforcement may not pay that taxpayer (Point b, Clause 5, Article 70).

What this Decree does not cover

Penalties for tax and invoice violations: Decree 125/2020/ND-CP (Clause 4, Article 74).
E-invoices: Article 26 of the Law and the invoice regulations. Decree 252 deals with invoices only in the suspension, disclosure and enforcement rules above.
Related-party transactions: the separate decree on tax administration for related-party transactions (Clause 7, Article 10).
Household and individual businesses: Decree 68/2026/ND-CP (Clause 9, Article 10).

Entry into force, replacement and transition (Articles 74 and 75)

In force from 1 July 2026 (Clause 1, Article 74), the same day as the Law on Tax Administration No. 108/2025/QH15.
Replaces Decrees 126/2020/ND-CP, 91/2022/ND-CP, 49/2025/ND-CP, 117/2025/ND-CP and 373/2025/ND-CP (Clause 3, Article 74). Decree 125/2020/ND-CP remains in force until it is replaced (Clause 4, Article 74).
Article 75 only sets who may reinstate debts written off by the chair of a provincial People’s Committee before 1 July 2026 that must be repaid under Clause 2, Article 21 of the Law. The other transitional rules are in Article 53 of the Law (exemptions and reductions arising before 1 July 2026, tax debts up to 30 June 2026, and audits already under way).

Need to check tax obligations before a suspension, a head office move, a profit remittance or a dissolution? See our legal retainer for companies in Vietnam and company dissolution in Vietnam.

Decree No. 252/2026/ND-CP detailing the Law on Tax Administration (English summary)