Decree No. 252/2026/NĐ-CP- issued on June 30, 2026, and taking effect on July 01, 2026 – Key new points to note

Decree No. 252/2026/NĐ-CP, Elaborating on a number of articles and measures for the organization and implementation of the Law on Tax Administration No. 108/2025/QH15, issued on June 30, 2026, and taking effect on July 01, 2026. Below are the key new points to note:

I. Tax Administration for E-Commerce and Digital Platforms

• Responsibility for Withholding, Declaring, and Paying Tax on Behalf (Article 43): Platform owners of e-commerce and digital platforms with online ordering and payment functions (regardless of whether they are domestic or foreign) must withhold, declare, and pay Value-Added Tax (VAT) and Personal Income Tax (PIT) on behalf of business households and individuals operating on the platform. For Foreign Suppliers (FSs), platform owners are responsible for withholding and paying VAT and Corporate Income Tax (CIT) on their behalf. If an FS has had its tax paid on its behalf by the platform, it is not required to self-declare foreign contractor tax.
• Responsibility for Providing Data (Article 60): Relevant organizations (owners of e-commerce platforms, digital asset services, logistics, international card organizations, etc.) must provide identification information and revenue data to the tax authority within 10 working days upon receiving a written request.
• Declaration of Receiving Accounts for Foreign Suppliers (Article 40): Upon initial tax registration in Vietnam, Foreign Suppliers are required to fully declare all bank accounts, e-wallets, or payment methods used to receive payments from Vietnamese customers.

II. Procedures for Tax Registration, Declaration, and Supplementary Submissions

• Automatic Data Synchronization (Article 6): When the National Population Database is connected with the tax authority, changes in personal information will be updated automatically; taxpayers (TPs) do not need to perform additional procedures.
• Time Limit for Supplementary Declaration (Article 1): Taxpayers are allowed to make supplementary tax returns within 05 years from the deadline for submitting the tax return (previously 10 years).
• Cases Where Supplementary Declaration Is Not Allowed (Article 12): Tax files that fall under the scope of an investigation as stated in a document from an investigative agency may not be supplemented.
• Handling Illegal Invoices (Article 12): If there is a court judgment or conclusion identifying acts of using illegal invoices, the buyer must make a supplementary declaration to adjust tax obligations, even if that tax period has already been inspected or audited.
• Deadline for Tax Registration:
  • Branches and transaction offices of credit institutions: 10 working days from the date of opening.
  • Dependents: No later than December 31 of the tax year.
  • Individuals subject to tax refunds without a Tax Identification Number (TIN): Must register prior to processing refund procedures.
  • Individuals relocating to another province: Must continue to fulfill outstanding procedures and obligations with the tax authority of the departing location.
• Cases Not Required to Submit Tax Declaration Files: Added the case where a Vietnamese party withholding and paying foreign contractor tax on behalf of others registers for monthly declaration, but no tax withholding arises during the month.

III. Fulfillment of Tax Obligations and Temporary Suspension of Exit

• Tax Debt Thresholds Subject to Temporary Suspension of Exit (Article 28):
  • Individuals/Business households: Tax debt of 50 million VND or more, overdue by 120 days.
  • Enterprises/Cooperatives: Tax debt of 500 million VND or more, overdue by 120 days.
  • TPs not operating at the registered address: After 120 days from the notification without restoring or terminating the TIN.
  • Foreigners or Vietnamese individuals exiting to reside abroad: Are subject to consideration for temporary exit suspension merely by having any overdue tax debt.
• Transparent Notification Process: 30 days prior to issuing a decision on temporary exit suspension, the tax authority must send a warning via the electronic system and make it public on its official portal.

IV. Tax Enforcement Measures

• Simultaneous Application of Multiple Measures (Article 65): Tax authorities may execute multiple enforcement measures simultaneously, instead of sequentially as previously required.
• Handling Asset Dispersal Acts (Article 65): Enforcement will be applied immediately upon detecting that a taxpayer is transferring, selling, or withdrawing assets unusually.
• Open Mechanism for Suspension of Invoice Use (Article 69): Taxpayers who are subject to enforcement via suspension of invoice use but need to issue invoices on a transaction-by-transaction basis can still be approved, provided they immediately pay at least 18% of the payment value into the state budget.

V. Priority Status for Compliant Taxpayers

• Priority for Automated Procedures (Article 48): Taxpayers ranked with good compliance for 02 consecutive years and ready to share real-time data will enjoy priority status, including:
  • Reduction of internal approval steps.
  • Auto-filling of tax return information.
  • Automated tax refunds/exemptions/reductions.
  • Exemption from inclusion in the plan for on-site tax audits (except in special high-risk cases).
• Recognition, Extension, or Revocation of Priority Status: Handled fully automatically on the IT system of the tax sector.