Luật Quản lý thuế 2025 (số 108/2025/QH15) - Toàn văn mới nhất

LAW ON TAX ADMINISTRATION

Pursuant to the Constitution of the Socialist Republic of Vietnam, amended by resolution No. 203/2025/QH15;

The National Assembly promulgates the Law on Tax Administration.

Chapter I

GENERAL PROVISIONS

Article 1. Scope

This Law provides for administration of taxes and other amounts payable to the state budget.

Article 2. Regulated entities

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a) Organizations, households, household businesses and individuals paying tax in accordance with tax laws;

b) Foreign organizations, foreign individuals doing business in Vietnam or earning income in Vietnam and paying tax in accordance with tax laws;

c) Foreign organizations, foreign individuals doing on e-commerce platforms or other digital platforms and paying tax in accordance with tax laws;

d) Organizations, households, household businesses and individuals paying other amounts to state budget as prescribed by law;

dd) Organizations and individuals withholding and paying withheld tax in accordance with tax laws, tax administration laws and relevant laws.

2. Tax administration authorities include tax authorities and customs authorities.

3. Tax administration officials include tax officials and customs officials.

4. Other relevant state authorities, organizations and individuals.

5. The Government of Vietnam shall elaborate Clause 1 and Clause 2 of this Article.

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1. Tax authorities shall categorize taxpayers according to the criteria specified in Clause 2 of this Article to determine the preferential treatments and distribution of management resources; implement tax administration measures, supervise fulfillment of tax obligations, implementation of tax administration procedures appropriate for each category; analyze and assess tax risks, level and history of compliance with tax laws of taxpayers.

2. Criteria of taxpayer categorization:

a) Sectors, industries, characteristics, forms of operation;

b) Business types, ownership structure;

c) Business scale, revenues, contributions to state budget;

d) Level and history of compliance with tax laws of taxpayers;

dd) Other criteria established by the Minister of Finance.

3. The Minister of Finance shall elaborate this Article.

Article 4. Definitions

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1. “tax” means a compulsory amount payable to the state budget by organizations, households, household businesses, individuals as prescribed by tax laws.

2. “other amounts payable to state budget collected by tax administration authorities” (hereinafter referred to as "other revenues") means revenues prescribed in Point b Clause 1 Article 38 of this Law.

3. “other amounts payable to state budget not collected by tax administration authorities” means revenues prescribed in Clause 6 Article 39 of this Law. For the purposes of this document, tax and other amounts payable to state budget are collectively referred to as "tax".

4. “tax debt” means tax, late payment interest, fines that the taxpayer fails to pay to the tax administration authority by the deadline prescribed by law.

5. "tax administration information system" means a centralized processing system that is integrated into a digital data platform to collect, process, store, update, and manage tax-related information and data for the purposes of providing digital services to taxpayers, support electronic tax administration, and apply technology to maximize automation of processes.

6. “premises" of a taxpayer means the location where the taxpayer partially or fully operate their business, including the headquarters, branches, stores, factories, goods storage, asset storage; residences or places where tax is incurred.

7. “tax identification number” or “TIN” means a series of digits and characters assigned by tax authorities to each taxpayer to serve tax administration.

8. "tax period" means a period of time for determination of tax payable to state budget as prescribed by tax laws, tax administration laws and other relevant laws. A tax period can be a separate occurrence, month, quarter or settlement period.

9. "tax dossier" means a application dossier for taxpayer registration, tax declaration or payment; extension of deadline for tax declaration, tax exemption, tax reduction, tax cancellation, tax debt freezing, tax debt cancellation, exemption of late payment interest or fines, exemption of late payment interest, tax deferral, deferral of tax debt payment, payment of tax debt by instalments, customs dossier.

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11. “tax risk” means the risk of non-compliance from taxpayers leading to loss of the state budget revenue.

12. “risk management in tax administration” means the tax administration authority's application of measures, processes and data analysis instruments to determine, assess, classify tax risks according to criteria established by the tax administration authority for the purposes of allocating resources, implementing appropriate management measures, focusing on high-risk cases and promptly controlling potential violations of tax administration laws.

13. "compliance management in tax administration" means the tax administration authority's use of documents, information, data on taxpayers to monitor, assess their compliance with tax laws, and implementation of appropriate management measures with an aim to encourage and support voluntary compliance, grant preferential treatments to compliant taxpayers, and promptly handle non-compliance cases.

14. “tax obligation fulfillment” means full payment of tax, late payment interest, fines for tax administration-related violations.

15. "commerce database" means a collection of economic, financial and commercial information and data collected, processed, standardized and provided on the market by data-trading organizations.

16. “taxpayer information” means information and data on taxpayers and their tax obligations provided by taxpayers or collected by state authorities, relevant organizations and individuals, and collected by tax authorities during the process of tax administration.

17. “related parties” means parties directly or indirectly participating in the management, control, capital contribution of enterprises; parties under direct or indirect management, control of an organization or individual; parties whose capitals are contributed by one organization or individual; enterprises managed, controlled by members of a family.

18. “related-party transaction” means a transaction between related parties.

19. “independent transaction” means a transaction between unrelated parties.

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21. "force majeure event" means an event in which the taxpayer suffers from physical damage caused by natural disasters, catastrophes, epidemics, fire, accidents, and other force majeure events prescribed by the Government.

Article 5. Contents of tax administration

1. Tax authorities shall carry out tax administration by taxpayer category.

2. Contents of tax administration include:

a) Taxpayer registration; tax declaration, calculation, deduction, payment of tax, late payment interest and fines; imposition of fixed tax amounts (hereinafter referred to as "tax liability"); tax refunds; settlement of overpaid tax, late payment interest and fines; tax exemption; tax reduction; non-imposition of tax; tax cancellation; tax debt freezing; tax debt cancellation; exemption of late payment interest and fines; calculation and cancellation of late payment interest; deferral of payment of tax, late payment interest and fines; extension of deadlines for submission of tax declaration dossiers; tax debt payment by instalments; tax enforcement;

b) Communication; assisting taxpayers; risk management, compliance management;

c) Management of taxpayer information;

d) Management of invoices and records;

dd) Tax inspection; implementation of measures against tax offences; imposition of administrative penalties for tax administration-related offences; handling tax-related complaints and denunciations;

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3. The contents of tax administration prescribed in Clause 2 of this Article shall also be applied by tax authorities to manage other amounts receivable prescribed by this Law and relevant Laws.

Article 6. Tax administration principles

1. Tax administration must be carried in a manner that ensures transparency and equality, with taxpayers placed at the center of service. It must safeguard the lawful rights and interests of taxpayers while enhancing the effectiveness and efficiency of state budget revenue management.

2. Taxpayers shall pay tax and other amounts payable to state budget as prescribed by tax laws and relevant laws. Taxpayers shall determine the amounts of tax and other amounts payable to state budget, make declaration and payment in accordance with tax laws, tax administration laws and relevant laws, except in cases where tax and other amounts are calculated and notified by tax administration authorities as prescribed by law.

3. Tax administration authorities, state authorities and other organizations of the State that are assigned to manage state budget revenues shall carry out tax administration in accordance with this Law and other relevant laws.

4. Principles applied to tax administration:

a) Substance‑over‑form principle: The nature of production, business activities and transactions determines the tax obligations, ensuring that transactions reflect the actual commercial, economic, and financial substance, regardless of the form of transaction expressed in the contract or document between the taxpayer and relevant parties;

b) Arm's length principle;

c) Risk management is based on the level of risk to ensure efficient use of resources and improve management effectiveness;

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dd) Tax administration must follow international practice and is adapted to Vietnamese' conditions.

Article 7. Confidentiality and disclosure of taxpayer information

1. Tax administration authorities, tax administration officials, former tax administration officials, agencies providing or exchanging taxpayer information, tax service providers (hereinafter referred to as "tax agents"), and customs service providers (hereinafter referred to as "customs agents") must keep taxpayer information confidential, except in cases where taxpayer information is provided or disclosed by tax administration authorities as prescribed in Clauses 2 and 3 of this Article.

2. Tax administration authorities shall provide taxpayer information in the following cases:

a) Taxpayer information is requested in writing by investigation authorities, Procuracies, Courts inspectorates, State Audit Office of Vietnam, other state management authorities to serve proceeding, audit, inspection as prescribed by law;

b) Taxpayer information is requested in writing by other competent authorities as prescribed by law;

c) Taxpayer information is provided to foreign tax authorities under international treaties and agreements on taxation to which the Socialist Republic of Vietnam is a signatory.

3. Tax administration authorities may disclose taxpayer information in the following cases:

a) Tax evasion; delaying payment of tax, late payment interest and fines; failure to pay outstanding tax, late payment interest and fines;

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c) Failure to comply with requests of tax administration authorities as prescribed by law.

4. Agencies, organizations, individuals receiving information from tax administration authorities in the cases prescribed in Clause 2 of this Article, tax administration authorities, other state authorities, relevant organizations in Vietnam and foreign countries, while providing, sharing, exchanging taxpayer information serving tax administration as prescribed in Articles 38, 39 and 40 of this Law, shall use the provided information for intended purposes and protect the confidentiality of provided information in accordance with this Law and relevant laws.

5. The Government of Vietnam shall elaborate Point c Clause 2 and Clause 3 of this Article.

Article 8. Prohibited activities in tax administration

1. Collusion, connivance, cover-up between taxpayers and tax administration officials, tax administration authorities for transfer pricing and/or tax evasion, commission of tax fraud, or misappropriation of tax and state budget revenues. Abuse of position or authority to disclose or leak taxpayer information against the law. Falsifying results of tax inspection or handling of tax offences. Harassing or causing difficulties for taxpayers. Misappropriating or unlawfully using collected tax.

2. Deliberate avoidance of declaration or incomplete, late, inaccurate declaration of tax payable, tax eligible for exemption, reduction, refund or cancellation. Obstructing tax administration officials in the performance of their duties. Resisting, delaying, or refusing to provide information and documents serving tax inspection and supervision.

3. Using TINs of other taxpayers to conduct violations against the law or allowing other persons to illegally use one’s TIN.

4. Selling goods, providing services without invoices as prescribed by law, using illegal invoices and records; using invoices and records illegally; forging invoices and records to commit violations of law. Creating invoices and records against the law or using them to commit tax administration-related offences.

5. Falsifying, misusing, unlawfully accessing, or destroying taxpayer information systems. Providing or disseminating false information in a manner that affects the reputation or operations of tax administration authorities, taxpayers, or tax management information systems.

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1. The tax administration force shall be built to be clean and strong; have public service ethics, passion for serving taxpayers, and compliance with administrative discipline and order; be equipped with and proficient in modern technology; and operate effectively and efficiently.

2. Tax administration officials shall have titles, standards, salaries, benefits, insignia, ranks, uniforms, and badges specific to tax administration officials in order to ensure effective tax administration, encourage responsibility, professionalism, and efficiency in the performance of official duties.

3. Tax administration authorities shall be responsible for training and building the force of tax administration officials so as to perform the functions of tax administration as prescribed by law.

4. The State shall ensure financial resources for activities of tax administration officials and tax administration authorities, including prioritized annual allocation of state funding for building and operating information technology systems, digital transformation in tax administration, electronic invoicing, facilities, equipment, and specialized tasks to improve the effectiveness of tax administration.

5. The Government of Vietnam shall elaborate Clause 2 and Clause 4 of this Article.

Chapter II

TAX ADMINISTRATION FUNCTIONS

Section 1. TAXPAYER REGISTRATION

Article 10. Taxpayer registration

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2. Taxpayer registration shall be applied for as the same time as registration enterprises, cooperatives, cooperative unions, artels, dependent units, other organizations, household businesses and individual businesses following the inter-agency single-window system.

3. Other cases not prescribed in Clause 2 of this Article shall apply for taxpayer registration directly with tax authorities.

4. Taxpayer registration deadlines; responsibilities of taxpayers, tax administration authorities, state authorities, organizations and individuals involved with taxpayer registration shall comply with regulations of the Government of Vietnam.

5. The Minister of Finance shall elaborate Clause 1 and Clause 3 of this Article.

Article 11. TIN

1. Tins of individuals, households, household businesses and individual businesses are the personal identification numbers of the individuals, owners of households, household businesses and individual businesses issued in accordance with regulations of law on identification.

2. TINs enterprises, cooperatives, cooperative unions, artels, dependent units, other organizations prescribed in Clause 2 Article 10 of this Law are their identification numbers issued as prescribed by law.

3. TINs of taxpayers other than those prescribed in Clause 1 and Clause 2 of this Article shall be issued by tax authorities and remain valid throughout their operations, from initial registration until invalidation.

4. TINs of organizations and individuals responsible for withholding and paying withheld tax on behalf of other taxpayers shall comply with regulations of the Minister of Finance.

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a) written on invoices, records, documents used for business transactions, tax-related administrative procedures and opening accounts at credit institutions, foreign bank branches, providers of payment services, providers of payment intermediary services;

b) Used for tax administration; exchanged, shared, provided for tax administration authorities.

6. The Government of Vietnam shall elaborate d Clause 5 of this Article.

7. The Minister of Finance shall elaborate Clauses 1, 2, 3 and 4 of this Article.

Section 2. TAX DECLARATION, CALCULATION AND WITHHOLDING

Article 12. Tax declaration, calculation and withholding

1. Taxpayers shall fully and accurately calculate and declare tax, except for tax to be calculated and notified by tax administration authorities according to regulations of the Government of Vietnam.

2. Foreign organizations and individuals doing business on e-commerce platforms and other digital platforms, and providing other services shall directly or authorize third parties to declare and pay tax in Vietnam, except the cases specified in Clause 3 of this Article.

3. Withholding tax; declaring and paying tax on behalf of taxpayers:

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b) Organizations and individuals responsible for declaring and paying tax on behalf of taxpayers as prescribed by tax laws and relevant laws shall declare and pay tax on behalf of taxpayers;

c) Taxpayers are not required to pay tax that have been withheld, declared and paid on their behalf.

4. Extension of submission deadlines for taxpayers that are unable to submit tax declaration dossiers punctually in the force majeure events prescribed in Clause 21 Article 4 of this Law:

a) The deadline for monthly, quarterly, annual and separate declaration of tax may be extended by up to 30 days from the initial deadline.

The deadline for tax settlement may be extended by up to 60 days from the initial deadline;

b) In cases where a further extension of the tax declaration deadline prescribed in Point a of this Clause is deemed necessary, the Government of Vietnam shall promulgate regulations in consideration of actual circumstances.

5. In case errors or omissions are found in a tax declaration dossier submitted to the tax authority, the taxpayer may submit a supplementary declaration within 05 years from the deadline for submission of the erroneous tax declaration dossier in the following cases:

 a) The supplementary documents are submitted before the tax authority or competent authority announces an inspection decision;

b) The tax declaration dossier is not subject to the scope and period of tax inspection or tax inspection specified in the inspection decision;

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d) In cases where the taxpayer discovers that the errors or omissions in the tax declaration dossier related to an inspection period causes an increase in tax payable, decrease in tax exempted, reduced, refunded, decrease in tax withheld, or decrease in overpaid tax, the taxpayer may submit a written explanation to the tax authority. If the explanation is deemed acceptable, the tax authority shall permit the taxpayer to revise the tax declaration dossier.

The taxpayer shall incur the same consequences as if the errors or omissions were identified by the tax authority or other competent authorities. The inspectors concerned shall be held responsible for the errors or omissions that were not discovered due to failure to comply with regulations of Point n Clause 1 Article 38 of this Law;

dd) The supplementary declaration is carried out under a conclusion or decision of the competent authority related to determination of the taxpayer's tax obligations. If the supplementary declaration leads to an increase in tax payable or a decrease in tax deducted, exempted, reduced or refunded, the taxpayer shall incur the same consequences as if the errors or omissions were identified by the tax authority or other competent authorities.

e) The Government shall specify the cases where investigation authorities prohibit supplementary declaration to serve investigation, and the responsibility of investigation authorities to notify tax authorities of the end of investigation prescribed in Point c of this Clause, and the cases in which supplementary declaration is carried out under a conclusion or decision of the competent authority related to determination of the taxpayer's tax obligations prescribed in Point dd of this Clause.

6. Customs dossiers of exports and imports under the Law on Customs shall be used as tax declaration dossiers. The declaration, supplementation declaration, tax declaration deadline extension, receiving customs authorities, exchange rates for calculation of tax on exports and imports shall comply with customs law.

7. The currency for tax declaration and calculation shall be Vietnamese Dong (VND). The Government of individual shall provide for the cases in which tax may be declared and calculated in foreign currencies.

8. The Government of Vietnam shall elaborate Clauses 1, 2, 3, 5, 6, 7 and Point b Clause 4 of this Article, and the following contents: Cases of exemption from submission of tax declaration dossiers; tax periods; deadlines for submission of tax declaration dossiers, except the cases specified in Clause 9 of this Article; declaration, calculation, payment of tax on petroleum activities and petroleum sale; exchange rates for tax declaration; declaration and determination of taxable prices for related-party transactions and Country-by-Country Report (CbCR); allocation of tax obligations; procedures for receiving and processing documents in case tax is calculated and notified by tax authorities.

9. The Minister of Finance shall elaborate Point a Clause 4 of this Article and the following contents: Deadlines for submission of declaration dossiers of agricultural land use tax, non-agricultural land use tax and other amounts payable to state budget; tax periods; tax declaration and payment; tax declaration dossiers; methods for submission of tax declaration dossiers; receiving authorities.

Article 13. Declaration, calculation and withholding tax payable by household businesses and individual businesses

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a) Household businesses and individual businesses with estimated annual revenue from business operations below the VAT or CIT threshold shall send notifications of actual annual revenue to tax authorities;

b) Household businesses and individual businesses with estimated annual revenue from business operations subject to tax shall determine the amounts of VAT and CIT payable as prescribed by VAT laws and CIT laws.

For household businesses or individual businesses using authenticated e-invoices or e-invoices generated by cash registers connected to tax authorities' network, the Tax Administration System shall automatically generate tax returns to assist them in declaring and calculating tax on the e-invoice database, tax administration database and other databases the tax authorities obtained from other state authorities, organizations and individuals.

2. Other taxes

Household businesses and individual businesses shall determine the amounts of other taxes payable as prescribed by tax laws and other relevant laws.

3. Household businesses and individual businesses shall declare and calculate each tax by tax period. On the basis of tax administration database, tax authorities shall provide information to assist household businesses and individual businesses declaring and calculating tax.

4. Regarding household businesses and individual businesses doing business on e-commerce platforms or digital platforms:

a) Owners of e-commerce platforms and other digital platform with online shopping and payment functions shall withhold tax, declare and pay the withheld tax on behalf of household businesses and individual businesses thereon;

b) Household businesses and individual businesses doing business on e-commerce platforms and other digital platform without online shopping and payment functions shall directly declare and pay tax as per regulations.

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6. The Minister of Finance shall specify the documentation and procedures for declaration of tax and revenue, tax payment and refund, and accounting regulations applicable to household businesses and individual businesses.

Section 3. Payment of tax, late payment interest and fines; deferral of payment of tax, late payment interest and fines; settlement of overpaid tax, late payment interest and fines; handling late payment of tax

Section 14. Payment of tax, late payment interest and fines; deferral of payment of tax, late payment interest and fines; settlement of overpaid tax, late payment interest and fines; handling late payment of tax

1. Deadlines for payment of tax, late payment interest and fines:

a) In case tax is calculated by taxpayers themselves, the tax payment deadline shall be the deadline for submission of the tax declaration dossier. In case of submission of supplementary declaration, the tax payment deadline shall be the deadline for submission of the erroneous tax declaration dossier. In case of quarterly payment of provisional tax, the payment deadline shall be prescribed by the Government of Vietnam;

b) In cases where tax is calculated, notified, settled by tax administration authorities, the deadline for payment of tax, late payment interest and fines shall be that written on the notifications or decisions issued by tax authorities as prescribed by law. In accordance with tax settlement documents are issued by competent authorities, the deadline for payment of tax, late payment interest and fines shall be that written on such documents.

During the process of settlement of complaints and lawsuits filed by taxpayers against the amount of tax, late payment interest and fines, the taxpayer still has to pay the amount tax, late payment interest and fines payable unless a competent authority issues a decision to suspend the tax notification or tax settlement document by the tax authority or competent authority.

c) Deadlines for payment of tax on exports and imports subject to tax under tax laws shall comply with the Law on Export and Import Duties; In cases where tax is incurred after customs clearance or conditional customs clearance is granted, tax payment deadline shall comply with regulations of the Minister of Finance.

2. Methods of payment of tax, late payment interest and fines:

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b) Direct payment at providers of payment services, payment intermediary services, other organizations with directly or indirect connection with Tax Administration Information System of tax administration authorities; competent authorities as prescribed by law; tax administration authorities; organizations authorized by tax authorities to tax administration authorities.

3. The currency for tax payment shall be the same currency used for tax declaration as prescribed in Clause 7 Article 12 of this Law.

4. After paying tax, late payment interest and fines, the taxpayer will be given a receipt. If the payment of tax, late payment interest and fines has been issued with a transaction identification number by the tax administration authority, the taxpayer shall make the payment using such transaction identification number.

When issuing payment receipts to taxpayers, authorities and organizations collecting tax, late payment interest and fines prescribed in Clause 2 of this Article shall also transfer information to tax administration authorities.

Transaction identification number is a series of characters generated by the Tax Administration Information System and is unique to each amount payable by a taxpayer.

5. Determination of date of payment of tax, other amounts, late payment interest and fines:

a) In case of online payment, the date of payment shall be the date the authority or organization prescribed in Point a Clause 2 of this Article withdraws money from the taxpayer's or the authorized payer's account, and that date shall be written on the payment receipt;

b) In case of direct payment, the date of payment shall be the date the authority or organization prescribed in Point b Clause 2 of this Article collects money from the taxpayer, and that date shall be written on the payment receipt.

6. Payment of export- and import-related fines shall comply with regulations of law on administrative penalties. Deferral of fine payment shall comply with this Law.

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a) The taxpayer’s business suffers material damage due to a force majeure events prescribed in this Law;

b) The taxpayer's business operation has to be suspended for relocation business premises at the request of a competent authority;

c) Special cases of deferral of tax, other amounts, late payment interest and fines prescribed by the Government of Vietnam. Deferral of tax, other amounts, late payment interest and fines does not lead to changes to the state budget revenue estimate decided by the National Assembly.

Taxpayers eligible for payment deferral as prescribed in this Clause shall not incur late payment interest on the deferred tax debt for the deferral period.

8. The Government of Vietnam shall elaborate Clause 1 of this Article and the following contents: time limits for collecting authorities and organization to transfer collected tax, other amounts, late payment interest and fines to state budget; deferral of payment of tax, other amounts, late payment interest and fines; documentation Decree procedures for payment of tax, other amounts, late payment interest and fines in the cases prescribed in Point c Clause 7 of this Article.

9. The Minister of Finance shall elaborate Clauses 2, 3, 4, 5, 7 of this Article and the following contents: review and processing of proofs of payment of tax, other amounts, late payment interest and fines, processing of applications for deferral of payment of tax, other amounts, late payment interest and fines, except the cases prescribed in Point c Clause 7 of this Article.

Article 15. Handling overpaid tax, other amounts, late payment interest and fines

1. Overpaid tax, other amounts, late payment interest and fines are amounts of paid tax, other amounts, late payment interest and fines in excess of the amounts payable.

2. Taxpayers having overpaid tax, other amounts, late payment interest and fines may offset the overpaid amounts against outstanding liabilities or claim a refund of the overpaid amounts if no tax debts remain. Offsetting between the same of different types of tax, other amounts, late payment interest and fines shall be automatically executed by the Tax Administration Information System or at the request of taxpayers in accordance with instructions of the Minister of Finance.

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3. Taxpayers who wish to claim refunds of overpaid tax, other amounts, late payment interest and fines shall comply with regulations of Article 18 of this Law.

4. Overpaid tax, other amounts, late payment interest or fine shall not be refunded in the following cases:

a) The taxpayer chooses not to receive the refund;

b) The taxpayer fails to offset the overpaid tax, other amounts, late payment interest and fines against outstanding liabilities and fails to claim a refund within 10 years from the date of overpayment.

5. The Minister of Finance shall elaborate this Article and the following contents: documentation and procedures for handling overpaid tax, other amounts, late payment interest and fines; timeframe for determination of overpaid tax, other amounts, late payment interest and fines; cases where offsetting is executed by the Tax Administration Information System or upon the taxpayer's request.

Article 16. Handling of late payment of tax and other amounts

1. Late payment interest shall be charged in the following cases:

a) The taxpayer pays tax or other amounts later than the deadline or extended deadline prescribed in Article 14 of this Law;

b) The taxpayer's supplementary declaration results in understatement of tax or other amounts payable or overstatement of tax or other amounts exempted, reduced, refunded or cancelled;

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d) The cases in which tax debt may be paid by installments as prescribed in Clause 6 Article 48 of this Law;

dd) The cases prescribed in Clause 8 Article 44 of this Law;

e) The cases in which administrative penalties prescribed in Point a Clause 2 Article 44 are not imposed for tax administration-related offences prescribed in Clause 2 Article 45 of this Law, and the cases prescribed in Point b Clause 2 Article 44 of this Law;

g) The authority or organization that is authorized by the tax administration authority to collect tax and other amounts or to manage state budget revenues but fails to transfer the collected amounts to state budget shall pay late payment interest on such amount;

h) Authorities and organizations that are required to withhold tax and other amounts payable by the taxpayers and pay the withheld amounts on behalf of the taxpayers but fail to fully or punctually transfer the withheld amounts shall pay late payment interest on behalf of the taxpayers;

i) Late payment interest on exports and imports covered by tax payment guarantee by credit institutions shall be paid in accordance with regulations of law on export and import duties.

2. Calculation of late payment interest:

a) The rate of late payment interest shall be 0,03% per day on the overdue amount payable to the tax authority or customs authority;

b) The late payment interest accrual period shall comply with regulations of the Government.

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4. In case the taxpayer fails to pay tax and other amounts within 30 days from the payment deadline, the tax authority shall notify the taxpayer of the tax debt and the number of overdue days.

5. Taxpayers may be exempt from paying the late payment interest specified in Clause 1 of this Article in the force majeure events specified in Clause 21 Article 4 of this Law.

6. The Government shall elaborate regulations on: adjustment of late payment interest prescribed in Point a Clause 2 of this Article according to actual socio-economic circumstances, late payment interest accrual periods, cases of late payment interest exemption and cancellation, and adjustment of late payment interest.

7. The Minister of Finance shall specify documentation, procedures and authority for handling late payment of tax and other amounts, exemption and cancellation of late payment interest prescribed in this Article.

Article 17. Fulfillment of tax obligations

1. Fulfillment of tax obligations in case of dissolution, bankruptcy, termination, non­-operation at registered address:

a) Fulfillment of tax obligations in case of dissolution of enterprises, cooperatives, cooperative unions shall comply with regulations of law on enterprises, credit institutions, insurance business, cooperatives and other relevant laws;

b) Fulfillment of tax obligations in case of bankruptcy of enterprises, cooperatives, cooperative unions shall comply with regulations of law on bankruptcy and rehabilitation;

c) In cases where a sole proprietorship, single-member limited liability company or partnership is terminated or not operating at its registered address without fulfillment of its tax obligations, its owner shall fulfill tax obligations in accordance with enterprise laws; In cases where a multiple-member limited liability company or joint stock company is terminated or not operating at its registered address without fulfillment of its tax obligations, its contributing shareholders or contributing partners shall fulfill tax obligations in accordance with enterprise laws;

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dd) In cases where a taxpayer's dependent is terminated or not operating at its registered address without fulfillment of its tax obligations, the taxpayer shall have the responsibility to fulfill tax obligations of the dependent unit;

e) Owners of sole proprietorships, owners of single-member limited liability companies, general partners,
owners of household businesses and individual businesses have the responsibility to fulfill tax obligations and other obligations related to tax dossiers of the sole proprietorships, limited liability companies, partnerships, household businesses and individual businesses that are not operating at their registered addresses.

2. Fulfillment of tax obligations and obligations related to tax dossiers in case of reorganization of enterprises, cooperatives and cooperative unions:

a) Before full division (split-up), the predecessor (original) enterprise, cooperative or cooperative union shall fulfill tax obligations and obligations related to tax dossiers. Otherwise, the successor enterprises, cooperatives or cooperative unions shall inherit the predecessor's rights and tax obligations;

b) Before partial division (spin-off), consolidation or acquisition, the original, consolidating or acquired enterprises, cooperatives or cooperative unions shall fulfill tax obligations and obligations related to tax dossiers. Otherwise, the spin-off, consolidated or acquiring enterprises, cooperatives or cooperative unions shall inherit the their rights and tax obligations;

c) Before conversion, the predecessor (original) enterprise shall fulfill tax obligations and obligations related to tax dossiers. Otherwise, the successor enterprise shall inherit the predecessor's rights and tax obligations;

d) The reorganization of an enterprise, cooperative or cooperative union does not change its tax payment deadline. In cases where the reorganized or newly established enterprise, cooperative or cooperative union fails to fully and punctually pay tax and other amounts, penalties shall be imposed as prescribed by law.

3. Fulfillment of tax obligations In cases where the taxpayer is dead, declared dead, missing or legally incapacitated by the court (hereinafter referred to as "decedent"):

a) The inheritor or the person assigned to administer the decedent's estate shall fulfill tax obligations of the decedent from the inherited assets. In cases where there is no inheritor or all inheritors refuse to receive the decedent's estate, the decedent's tax obligations shall be fulfilled in accordance with civil laws.

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c) In cases where the court issues a decision on cancellation of a prior decision to declare a person dead or legally incapacitated, any tax debt previously cancelled under Article 21 of this Law shall be reinstated but late payment interest shall not be charged for the period over which the person was declared dead or legally incapacitated;

d) The administrator of estate of the person declared missing by the court fulfill the missing person's tax obligations using the missing persons' property under the court's decision.

4. Taxpayers shall fulfill tax obligations in case change of address leads to change of supervisory tax authorities, unless it is change of administrative boundaries as prescribed by law.

5. Cases in which tax obligation must be fulfilled before exit:

a) Individual businesses, owners of household businesses, individuals who are beneficial owners of enterprises, cooperatives, cooperative unions that have not fulfilled tax obligations under tax enforcement decisions;

b) Individual businesses, owners of household businesses, individuals who are beneficial owners of enterprises, cooperatives, cooperative unions that have not fulfilled tax obligations and no longer operate at their registered addresses;

c) Vietnamese nationals exiting Vietnam to reside overseas; Vietnamese nationals residing overseas, foreigners who have not fulfilled their tax obligations.

The Government shall specify the tax debt threshold that triggers an exit ban, in accordance with entry and exit laws.

6. Fulfillment of tax obligations upon transfer of investment projects and transfer of capital:

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a) In cases where organizations established under foreign laws or foreign nationals not residing Vietnam transfer investment projects or capital directly or indirectly to organizations established under the law of Vietnam or resident individuals of Vietnam, the transferee shall determine, declare, withhold and pay tax on behalf of the transferor. In case both the transferor and the transferee are organizations established under foreign laws or foreign nationals not residing Vietnam, the organization established under the law of Vietnam in which the transferor directly or indirectly invest shall declare and pay tax on behalf of the transferor in accordance with tax laws.

7. The Government of Vietnam shall elaborate this Article.

Section 4. REFUND OF TAX, OTHER AMOUNTS, LATE PAYMENT INTEREST, FINES; EXEMPTION OF TAX AND OTHER AMOUNTS; REDUCTION OF TAX AND OTHER AMOUNTS; TAX CANCELLATION; NON-IMPOSITION OF TAX

Article 18. Refund of tax, other amounts, late payment interest and fines

1. Cases of refund of tax, other amounts, late payment interest and fines:

a) Refund of tax to organizations and individuals eligible for tax refund as prescribed by tax laws;

b) Refund of overpaid tax, other amounts, late payment interest and fines to eligible organizations and individuals prescribed in Article 15 of this Law;

c) Refund of tax, other amounts, late payment interest and fines prescribed in Point a and Point b of this Clause to eligible individuals who are dead, declared dead, missing or legally incapacitated by the court: In this case, the inheritor or person assigned by the court to administer the eligible person's estate will receive the refund in accordance with civil laws.

2. The taxpayer eligible for refund of tax, other amounts, late payment interest or fines as prescribed in Clause 1 of this Article (hereinafter referred to as "tax refund") shall prepare and send a tax refund application to the competent tax administration authority.

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4. Tax authorities shall carry out automatic tax refund on the basis of database, risk management criteria, automated processes and information security measures. Tax authorities shall deploy automatic tax refund in multiple stages, aligned with actual circumstances, infrastructure capacity and application of information technology.

5. Authority to decide tax refund and tax refund reversal:

a) Heads of tax administration authorities shall decide tax refunds, except in the cases prescribed in Point b of this Clause;

b) Tax authorities shall decide automatic tax refunds prescribed Clause 4 of this Article;

c) Heads of tax administration authorities shall decide reversal of tax refunds in the cases prescribed in Clause 1 and Clause 4 of this Article.

6. The Government of Vietnam shall elaborate Clause 1 of this Article and the following contents: cases of rejection of tax refund; cases of refund before tax inspection and refund after tax inspection; time limits for receiving, processing tax refund applications by tax administration authorities.

7. The Minister of Finance shall elaborate Clauses 2, 3, 4 and 5 of this Article and the following contents: procedures for tax refund and tax refund reversal; responsibility for receiving, processing tax refund applications by tax administration authorities; offsetting refundable tax against tax debts.

Article 19. Exemption of tax and other amounts; reduction of tax and other amounts; tax cancellation; non-imposition of tax

1. Cases of exemption of tax and other amounts; reduction of tax and other amounts; tax cancellation; non-imposition of tax:

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b) Exemption of non-agricultural land use tax for households and individuals paying tax annually as per regulations of the Government of Vietnam; exemption of personal income tax for individuals incurring tax after annual settlement of personal income tax on salaries/wages and other tax at the rates prescribed by the Government of Vietnam.

2. The taxpayer eligible for exemption of tax and other amounts (hereinafter referred to as "tax exemption"), reduction of tax and other amounts (hereinafter referred to as "tax reduction) as prescribed in Clause 1 of this Article, tax cancellation or non-imposition of tax shall prepare and send an application to the competent tax administration authority.

3. Tax authorities shall carry out automatic tax exemption and tax reduction on the basis of database, risk management criteria, automated processes and information security measures. Tax authorities shall deploy exemption and tax reduction in multiple stages, aligned with actual circumstances, infrastructure capacity and application of information technology.

4. Authority to decide tax exemption, tax reduction, tax cancellation, non-imposition of tax:

a) Heads of tax administration authorities shall decide tax exemption, tax reduction, tax cancellation, non-imposition of tax, except the cases prescribed in Point b of this Clause;

b) Tax authorities shall decide automatic tax exemption and tax reduction in the cases prescribed Clause 3 of this Article;

c) Heads of tax administration authorities shall decide reversal of tax exemption and tax reduction in the cases prescribed in Clause 1 and Clause 3 of this Article.

5. The Government of Vietnam shall elaborate Clause 1 of this Article and the following contents: time limits for receiving and processing applications for tax exemption, tax reduction, tax cancellation, non-imposition of tax.

6. The Minister of Finance shall elaborate Clauses 2, 3, 4 of this Article and the following contents: applications for tax exemption, tax reduction, tax cancellation, non-imposition of tax; responsibility of tax administration authorities to receive and process applications for tax exemption, tax reduction, tax cancellation, non-imposition of tax; procedures for granting tax exemption, tax reduction, tax cancellation, non-imposition of tax, reversal of tax exemption and reduction.

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Article 20. Freezing of tax debts

1. A tax debt shall be frozen in the following cases:

a) The taxpayer is dead, declared dead, missing or legally incapacitated by the court;

b) The taxpayer has submitted a dissolution decision to the business registration authority for initiation of dissolution procedures, and the business registration authority has changed the taxpayer's status to "undergoing dissolution" on the National Business Registration Information System but the taxpayer has not completed dissolution procedures;

c) The court has issued the notice of receipt of the petition for bankruptcy or a request for tax debt freezing in accordance with regulations of law on bankruptcy and rehabilitation;

d) The taxpayer no longer operates at the address registered with the business registration authority or tax administration authority;

dd) The taxpayer's business/enterprise/ cooperative/artel/household business/ registration certificate, establishment and operation license, practicing license, branch/representative office/business location registration certificate, e-commerce platform-based business registration certificate/license has been revoked by a competent authority;

e) The taxpayer's right to use allocated or assigned land or minerals is effectively restricted due to causes originating from a competent state authority, which results in financial obligations related to land or minerals.

2. Heads of tax administration authorities have the power to issue and invalidate decisions on tax debt freezing.

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4. During the period when tax debts are frozen, late payment interest will be temporarily exempted. After the decision on tax debt freezing ceases to be effective, the tax administration authority shall calculate the full amount of late payment interest accrued from the tax payment deadline as prescribed, except for the case specified at Point e Clause 1 of this Article.

5. The Government of Vietnam shall elaborate this Article and the following contents: time and amount of tax debts eligible for freezing; cases of invalidation of tax debt freezing decisions; responsibility of state authorities, methods and criteria for identification of cases prescribed Point e Clause 1 of this Article.

6. The Minister of Finance shall specify procedures and documentation for freezing tax debts.

Article 21. Tax debt cancellation

1. A tax debt shall be cancelled in the following cases:

a) The individual is dead, declared dead, missing or legally incapacitated by the court and does not have any estate, including inherited assets;

b) The enterprise, cooperative, cooperative union is declared bankrupt by the court and has fulfilled its liabilities in accordance with regulations of law on bankruptcy and rehabilitation;

c) It is not the cases specified in Point a and Point b of this Clause, where the tax administration authority has implemented the enforcement measure prescribed in Point h Clause 1 Article 49 of this Law, the tax debt has been overdue for more than 10 years and is deemed unrecoverable;

d) Late payment interest is exempted due to a natural disaster, calamity, epidemic as prescribed in Clause 5 Article 16 of this Law, tax, other amounts, late payment interest and fines are deferred as prescribed in Point a Clause 7 Article 14 of this Law, but business remains unrecoverable and tax cannot be collected.

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4. The Government of Vietnam shall elaborate Point d Clause 1 of this Article and the following contents: authority to cancel tax debts; time limits for processing applications for tax debt cancellation; responsibility of organizations and individuals to cooperate in collecting cancelled tax debts.

5. The Minister of Finance shall specify documentation and procedures for tax debt cancellation, and the cases prescribed in Points a, b, c Clause 1 and Clause 2 of this Article.

Section 6. TAX INSPECTION

Article 22. Tax inspection

1. Tax inspection principles:

a) Apply risk management and information technology to tax inspections; prioritize electronic data-based online and remote inspections;

b) Tax inspections must comply with regulations of law and must not obstruct normal operation of taxpayers;

c) Tax inspections are meant to assess the completeness, accuracy and truthfulness of tax declaration, tax payment and compliance with tax laws of taxpayers;

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dd) Inspections of values of related-party transactions of taxpayers shall be conducted according to arm's length principles and economic substance of the activities or transactions that determine the tax obligations corresponding to the value derived from such economic substance; related-party transactions that fail to comply with arm's length principles and thereby reduce the enterprise's tax obligations, shall not be recognized.

2. Tax inspections at tax authorities’ premises:

a) Tax inspections on tax authorities’ premises shall be conducted on the basis of tax dossiers and tax administration database on the Tax Administration Information System; Customs authorities shall conduct physical inspection of exports and imports where necessary and feasible;

b) Tax administration authorities are entitled to request taxpayers to provide explanation, supplementary documents and information; issue tax liability imposition decisions, administrative penalties, or convert to conducting tax inspections at the taxpayer's premises;

c) Post-clearance inspection shall be carried out in accordance with customs law.

3. Tax inspections at taxpayers’ premises (on-site tax inspections):

a) Tax authorities shall carry out tax inspections in the following cases: the taxpayer's dossier is subject to tax inspection before refund; the taxpayer's dossier is eligible for refund before inspection according to risk management criteria and less than 05 years have elapsed since the issuance date of the tax refund decision; tax offences are suspected; the taxpayer is selected under a plan or scheme; tax inspection is requested by a competent authority or person; the taxpayer poses high risk of tax offences in the following circumstances: full division, partial division, acquisition, consolidation, conversion, bankruptcy, dissolution, termination (closure), equitization, TIN invalidation, business location relocation; the cases specified in Point b Clause 2 of this Article; tax inspection is necessary for settlement of tax-related complaints or denunciations; the taxpayer's application for tax exemption/reduction/cancellation poses high risks of tax offences;

b) Customs authorities shall conduct tax inspections at taxpayers' premises in the cases specified in Point a of this Clause; post-clearance inspection shall be conducted in accordance with customs law; inspection of eligibility for application of tax policies shall be conducted in accordance with relevant laws.

During inspections, customs authorities shall conduct physical inspection of exports and imports where necessary and feasible;

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d) A tax inspection must not last longer than 20 days from the day on which the tax inspection decision is announced. This 20-day time limit may be extended once for up to 20 more days. For enterprises with related-party transactions, the time limit shall be 40 days may be extended once for up to 40 more days. In cases where it is necessary to exchange information with foreign tax authorities, time limit for tax inspection may be extended for up to 02 more years.

The time limit specified in this Point excludes any period of inspection suspension notified by the tax authority.

4. Rights and obligations of taxpayers during tax inspections:

a) The rights of taxpayers during tax inspections shall be exercised in accordance with Point e and Point r Clause 1 Article 37 of this Law and regulations of law on specialized inspections;

b) The rights of taxpayers during tax inspections shall be exercised in accordance with Point e and Point r Clause 2 Article 37 of this Law and regulations of law on specialized inspection;

5. Duties and entitlements of the tax administration authorities during tax inspections:

a) Heads of tax administration authorities have the following duties and entitlements: issue, revise, annul tax inspection decisions; direct inspection teams to comply with the contents and timing writing in tax inspection decisions; implement the measures prescribed in Article 23 of this Law; suspend, postpone, or extend the inspection periods; impose tax administration-related penalties thin their competence, or issue inspection conclusions, inspection result notifications, or propose issuance of conclusions and decisions on administrative penalties for tax administration violations to competent persons; transfer dossiers to inspection authorities for inspection of complex or extensive cases, or transfer inspection dossiers to investigation authorities in accordance with law where tax inspections reveal acts of tax evasion or tax fraud subject to criminal prosecution; settle complaints and denunciations within their competence;

b) The chief of the inspection team has the following duties and entitlements: organize and direct team members to comply with the contents of the tax inspection decision; request taxpayers to provide information, documents, and explanations related to the tax inspection; apply measures prescribed in Clause 2 Article 23 of this Law; decide to seal documents or goods (if any) of the inspected entity where tax offences are suspected; prepare tax inspection records; where the tax inspection record specifies the administrative violations, it shall be deemed an administrative violation record; report inspection results to the person who issued the tax inspection decision;

c) Members of the inspection team, during tax inspections, have the following duties and entitlements: perform tasks assigned by the chief of the tax inspection team; request taxpayers to provide information, documents, and explanations related to the tax inspection content assigned; report the results of assigned tasks to the head of the tax inspection team.

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a) Cases of re-inspections:

After a case has been concluded and penalties have been imposed for tax administration-related violations, the tax authority shall conduct a re-inspection in the following cases: the tax inspection decision was issued ultra vires; there are violations of procedures during the inspection process leading to errors in the content of the inspection conclusion or the decision on imposition of penalties for tax administration-related violations; there are errors in the application of law in handling tax administration-related violations or in inspection conclusions; the inspection conclusion or decision on imposition of penalties for tax administration-related violations is inconsistent with evidence collected during the inspection; the person issuing the tax inspection decision, the chief or members of the inspection team intentionally falsify case files or intentionally issue unlawful conclusions or decisions on imposition of penalties for tax administration-related violations; there are signs of serious tax offences committed by the taxpayer within the scope of the tax inspection decision that were not fully detected during the tax inspection.

Customs authorities shall conduct re-inspections in cases where there are signs of tax offences committed by taxpayers within the scope of the tax inspection decision but such violations have not been discovered or handled, or have been concluded but not fully or accurately;

b) Authority to conduct re-inspection: the superior tax administration authority shall conduct re-inspections of cases handled by its inferior tax administration authorities;

c) Time limit for re-inspection shall comply with Point d Clause 3 of this Article;

d) Prescriptive period for re-inspection shall be 02 years from the day on which the inspection conclusion or the decision on imposition of penalties for tax administration-related violations is signed;

dd) When conducting a re-inspection, the person who issued the tax inspection decision, the chief and members of the inspection team shall exercise their duties and entitlements as prescribed in Clause 5 of this Article.

7. The Minister of Finance shall elaborate this Article.

Article 23. Measures implemented in suspected tax evasion cases

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a) Heads of the tax administration authorities are entitled to request organizations and individuals related to suspected tax evasion cases to provide information, whether in writing or in person. Tax authorities are entitled to assess accounting software, e-invoices, cash registers of taxpayers suspected of tax evasion;

b) The organizations and individuals requested to provide information as prescribed in Point a of this Clause have the responsibility to provide information accurately and punctually to the provided address, and take responsibility for the accuracy and truthfulness of the provided information.

2. Impoundment of documents related to suspected tax evasion cases:

a) Heads of the tax administration authority and chiefs of tax inspection teams shall issue decisions to impound documents related to suspected tax evasion cases;

b) Document impoundment shall be carried out when it is necessary to investigate the tax evasion;

c) When impounding documents related to suspected tax evasion cases, chiefs of tax inspection teams shall prepare impoundment records and preserve the impounded documents;

d) The tax administration authority shall give 01 copy of the impoundment decision and impoundment record to the document owner.

Section 7. TAX LIABILITY IMPOSITION

Article 24. Tax liability imposition

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a) Tax liability shall be imposed on the basis of tax administration rules, tax calculation methods and bases specified by tax laws and customs laws;

b) Tax administration authorities shall impose tax liability, separate elements or tax calculation bases.

2. Cases of tax liability imposition by tax authorities:

a) The taxpayer fails to apply for taxpayer registration; fails to declare tax; fails to provide supplementary tax documents as requested by the tax authority; fails to declare fully and/or accurately the tax calculation bases;

b) The taxpayer submitted the tax declaration dossier without determining the elements based on which tax is calculated, or fails to calculate the tax amount payable based on the determined elements;

c) The taxpayer fails to record or fully and accurately record data on the accounting books to determine tax obligations;

d) The taxpayer fails to present the accounting books, invoices, records and necessary documents relevant to the determination of tax payable within a certain time limit;

dd) The taxpayer fails to comply with the tax inspection decision;

e) The taxpayer declares tax according to values of goods/services against their market prices, thereby reducing tax obligations;

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h) The taxpayer uses documents that do not reflect the substance or actual value of the transactions to reduce tax obligations; makes false transactions to reduce tax obligations;

i) The taxpayer fails to fulfill the responsibility to declare and valuate related-party transactions, or fails to provide information about enterprises having related-party transactions according to tax administration laws.

3. The Government of Vietnam shall elaborate the following contents: basis and methods for tax liability imposition; authority and procedures for tax liability imposition; responsibility of taxpayers, declarants and tax authorities for tax liability imposition.

Article 25. Tax liability imposition on exports and imports

1. Customs authorities shall impose tax liability on exports and imports in the following cases:

a) The taxpayer declares or calculates tax according to illegal documents, records or data; fails to declare or accurately and fully declare information serving tax calculation;

b) The taxpayer fails to provide, refuses to provide or delays providing accounting books, documents, records and data serving calculation of tax payable or tax eligible for exemption, reduction, refund, cancellation or non-imposition by the deadlines prescribed by customs law, relevant laws or under written requests of customs authorities;

c) The taxpayer fails to prove, explain or punctually explain the contents related to tax calculation as prescribed by law;

d) The taxpayer fails to record or fully, truthfully and accurately record data on the accounting books, documents, records, data serving tax calculation;

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e) The transaction is falsely conducted in a manner inconsistent with their economic substance and actual occurrence, thereby affecting the amount of tax payable or tax eligible for exemption, reduction, refund, cancellation or non-imposition;

g) The taxpayer fails to calculate the amount of tax payable themselves;

h) The taxpayer fails to comply with the tax inspection decision issued by the customs authority;

h) Other cases of unconformable tax declaration or calculation discovered by customs authorities.

2. The customs authority shall impose tax liability according to the exports or imports in reality; the tax calculation bases and methods; the tax administration database and commerce database; customs dossiers; accounting books, documents, records; inspection results and conclusions of competent authorities or effective judgment or decision of the court, and other information relevant to the exports and imports.

3. The Government of Vietnam shall elaborate Clause 1 and Clause 2 of this Article and the following contents: methods for tax liability imposition; authority and procedures for tax liability imposition; responsibility of taxpayers, declarants and customs authorities for tax liability imposition.

Chapter III

ELECTRONIC INVOICES AND ELECTRONIC RECORDS

Article 26. Electronic invoices

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2. Electronic invoices include authenticated e-invoices, unauthenticated electronic invoices, electronic invoices generated by cash registers connected with tax authorities' system.

3. Intended users of electronic invoices:

a) Taxpayers shall use authenticated e-invoices, unauthenticated electronic invoices, electronic invoices generated by cash registers connected with tax authorities' system in accordance with regulations of the Government of Vietnam;

b) Household businesses and individual businesses that are not qualified to use authenticated electronic invoices under regulations of the Government, enterprises, business organizations and other organizations that need to provide electronic invoices for their customers must declare and pay tax before being issued with authenticated electronic invoices by tax authorities for separate goods sales and service provisions.

4. Electronic invoice-related services include creation, transmission, storage of authenticated e-invoices, unauthenticated electronic invoices, electronic invoices generated by cash registers connected with tax authorities' system. Providers of electronic invoice-related services shall satisfy technical requirements, personnel requirements, ensure information safety and data security as per regulations of the Minister of Finance, and shall cooperate with tax authorities in exchanging and providing information serving tax administration.

5. Rules, rights and responsibilities for issuance, management and use of electronic invoices:

a) Organizations, household businesses and individual businesses shall issue electronic invoices when selling goods/services. The invoices must follow standard formats, contain sufficient information in accordance with tax laws and accounting laws, fully and accurately reflect the business transaction. Invoice issuers shall bear legal responsibility for the accuracy of the invoices they issued, unless electronic invoices are not required as per regulations of the Government;

b) The registration, management and use of electronic invoices shall comply with regulations of law on electronic transactions, accounting and tax;

c) The timing for electronic invoice issuance shall comply with regulations of the Government;

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dd) The electronic invoice database shall be used to develop the invoice database; connected to and share with relevant agencies and organizations to serve state management and protection of buyers' interests.

Tax authorities shall organize, develop, manage and operate the electronic invoice data system. Based on results of risk analysis, tax authorities shall implement appropriate management measures, including termination and suspension of use of electronic invoices in case of high risks related to tax and invoicing;

e) Providers of electronic invoice-related services shall establish a mechanism for inspecting, detecting, warning and providing information for tax authorities;

g) Buyers have the right and responsibility to request sellers to provide electronic invoices when buying goods and services; are entitled to preferential measures as prescribed by law.

6. The Government of Vietnam shall elaborate the following contents: types of electronic invoices; intended users; contents and timing of electronic invoices; cases of exemption from use of electronic invoices; cases of using electronic invoices free of charge; duties, entitlements, responsibilities of organizations and individuals for management and use of electronic invoices.

7. The Minister of Finance shall elaborate the following contents: registration for use of electronic invoices; electronic invoice formats; authorization of electronic invoice issuance; processing electronic invoices issued; samples of electronic invoice symbols and designs; criteria for identification of high-risk applicants; cases of termination and suspension of use of electronic invoices; measures for encouraging buyers to take invoices when buying goods and services, and rewarding consumers who report sellers that fail to issue and provide electronic invoices using state funding in annual recurrent expenditure estimate as prescribed by law.

Article 27. Electronic records

1. Electronic records are documentary evidence for collection of tax, fees, charges or deduction of tax in the form of electronic data, issued by tax administration authorities or responsible organizations to taxpayers by electronic means.

2. Rules for issuance, management and use of electronic records:

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b) Organizations issuing electronic records shall fully and accurately recognize transactions, and take legal responsibility for the accuracy of documents they issued.

3. Electronic record-related services include creation, transmission, storage of electronic records. Providers of electronic record-related services shall satisfy technical requirements, personnel requirements, ensure information safety and data security as per regulations of the Minister of Finance.

4. The Government shall elaborate the following contents: electronic records, contents and issuance timing of electronic records; methods for issuance of electronic records; electronic administrative tax documents; connection, transmission of electronic record data; cases of service charge exemption; duties, entitlements, responsibilities of organizations and individuals for management and use of electronic records.

5. The Minister of Finance shall elaborate the following contents: registration for use of electronic records, electronic record formats; processing of electronic records issued; samples of electronic record symbols and designs.

Chapter IV

INTERNATIONAL COOPERATION IN TAXATION AND INTERNATIONAL TAX ADMINISTRATION

Article 28. Scope of international cooperation in taxation and international tax administration

1. Conclusion, participation in international treaties, international agreements, international forums and other international organizations.

2. Implementation of international treaties and agreements on taxation to which the Socialist Republic of Vietnam is a member or signatory to serve tax administration.

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Article 29. Rules for international cooperation in taxation and international tax administration

1. Respect for national sovereignty, equality, and mutual benefit among parties.

2. Compliance with international treaties and agreements on taxation to which the Socialist Republic of Vietnam is a member or signatory.

3. Assurance of confidentiality of information and protection of taxpayers’ lawful rights and interests in accordance with the laws of Vietnam, international treaties and agreements to which the Socialist Republic of Vietnam is a member or signatory, and relevant tax-related international commitments.

Article 30. Contents of international tax administration by tax administration authorities

1. Subject matters of international tax administration are organizations and individuals regulated by international treaties and agreements on taxation to which the Socialist Republic of Vietnam is a member or signatory.

2. Duties of tax administration authorities in international tax administration:

a) Advise and assist the Minister of Finance in proposing competent authorities or persons to sign and implement rights, obligations, and safeguard the interests of the Socialist Republic of Vietnam under international treaties;

b) Negotiate, sign, and implement international commitments on taxation to carry out Double Taxation Agreements (DTAs), including: Mutual Agreement Procedures (MAP) and Advance Pricing Agreements (APA).

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c) Negotiate, sign, and implement international commitments on taxation related to exports and imports;

d) Provide guidance on implementation and process applications for implementation of DTAs and other international tax treaties;

dd) Collect and exchange taxpayer information and cooperate in tax administration with foreign tax authorities under international treaties, agreements to which the Socialist Republic of Vietnam is a member or signatory, and international taxation forums to serve tax administration;

e) Cooperate with and provide other administrative assistance on taxation for foreign tax authorities and international organizations in accordance with the law of Vietnam and international treaties/agreements to which Vietnam is a member or signatory;

g) Implement regulations on Global Minimum Tax, tax administration of enterprises with related-party transactions, and fulfill other member's obligations under international treaties or agreements to which the Socialist Republic of Vietnam is a member or signatory;

h) Organize the collection and verification of information from agencies, organizations, and taxpayers in line with the information exchange standards of the Global Forum on Transparency and Exchange of Information for Tax Purposes.

3. The Minister of Finance shall specify contents, procedures for signing and implementing international commitments prescribed in Point b Clause 2 of this Article.

4. The Government of Vietnam shall elaborate Points e, g and h Clause 2 3 of this Article.

Article 31. Rules for implementation of MAP and APA

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2. The application of the APA mechanism shall be based on the taxpayer’s request and the consensus between the tax authority and the taxpayer, through unilateral, bilateral, or multilateral agreements between the tax authority, the taxpayer, and the foreign tax authority of the relevant country or territory, as decided by the head of the tax authority in accordance with the regulations of the Minister of Finance.

3. The application of the APA mechanism must rely on taxpayer information and databases used in tax administration for enterprises with related-party transactions, including: commercial databases; tax administration databases; information and data of enterprises disclosed on the stock market; information and data published on domestic and international commodity and service exchanges; information and data published or officially provided for the tax administration authorities by ministries, central authorities, and state authorities in accordance with law; and information obtained through international cooperation in taxation exchanged by tax authorities of countries and territories under double taxation agreements, tax administrative assistance agreements, and multilateral information-sharing mechanisms.

4. An APA shall take effect from the tax period in which it is signed, or from the year succeeding the year in which it is signed, depending on the agreement between the tax authority and the taxpayer therein.

Chapter V

RISK MANAGEMENT, COMPLIANCE MANAGEMENT, APPLICATION OF TECHNOLOGY, DATA AND DIGITAL TRANSFORMATION TO TAX ADMINISTRATION

Article 32. Rules for application of risk management, compliance management and digital transformation to tax administration

1. Tax administration authorities shall apply risk management and compliance management to:

a) Improve the effectiveness of tax administration, optimize resources of tax administration authorities;

b) Create a transparent and fair business environment; encourage taxpayers to voluntarily comply with tax laws; protect lawful rights and interests of taxpayers;

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2. Rules for application of risk management and compliance management:

a) Ensure objectivity, transparency, compliance with law, and non-discrimination;

b) It is based on analysis of objective, comprehensive and up-to-date data;

c) Apply management measures appropriate for the characteristics, level of compliance and risk of each group and type of taxpayers;

d) Prioritize application of modern information technology and automation to collection, analysis of data, classification of compliance and risk levels.

3. Tax administration authorities shall implement digital transformation and automation of tax administration works based on application of science, technology and big data.

4. Transactions between taxpayers and tax administration authorities shall be conducted electronically via the Tax Administration Information System, except in special cases prescribed by the Government of Vietnam.

5. Agencies and organizations shall use electronic records provided by tax administration authorities and must not request taxpayers to present physical documents if the data is already available in the common database of state authorities.

6. The Government of Vietnam shall elaborate d Clause 4 of this Article.

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1. Tax authorities shall apply risk management to administration of taxpayer registration, tax declaration, tax payment, tax debts, tax enforcement, tax refund, tax inspection, tax inspection, management and use of invoices, records and other tax administration tasks.

2. Customs authorities shall apply risk management to decide tax inspections during customs procedures and other customs tasks related to export, import, and transit of goods as prescribed by customs laws.

3. Risk management in tax administration includes collection and processing tax-related information; development of criteria, organization of evaluation and classification of risk levels in tax administration; organize implementation of appropriate tax administration measures.

4. Tax administration authorities shall utilize the Tax Administration Information System so as to integrate and process data for the application of risk management and automation in tax administration.

5. The Minister of Finance shall elaborate the following contents: criteria for evaluation and classification of risk levels, and application of risk management in tax administration.

Article 34. Compliance management in tax administration

1. Tax authorities shall implement compliance management to effectively allocate resources, encourage voluntary compliance and create a fair business environment, including:

a) Developing a system for evaluation and classification of levels of compliance with tax laws of taxpayers, while maintaining electronic dossier of each taxpayer, including information about: frequency of tax offences; nature and seriousness of the offences; level of cooperation with tax administration authorities in tax-related procedures, tax inspection and compliance with penalization decisions, and other information about tax obligations;

b) Combining propaganda and assisting, encouraging taxpayers to voluntarily comply with inspection and supervision measures based on evaluation of compliance and risks of taxpayers;

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The Government shall elaborate the conditions, scope and forms of prioritizing compliant taxpayers.

2. Customs authorities shall organize uniform compliance management of taxpayers, including: compiling and managing taxpayers' dossiers; developing criteria, indicators and organizing evaluation of taxpayers' compliance; assisting, encouraging taxpayers to improve compliance capacity; implementing inspection, supervision, post-customs clearance inspection and other techniques depending on taxpayers' compliance as per regulations of law.

3. The Minister of Finance shall stipulate criteria for evaluation of taxpayers' compliance and compliance management activities in tax administration.

Article 35. Tax Administration Information System

1. The Tax Administration Information System is a concentrated and integrated processing system that provides comprehensive online public services and digital services for taxpayers; ensures the collection, processing, storage, updating, and management of information and data accurately, fully, and promptly. The entire process is recorded and stored as history in the system.

2. The tax administration database is built, developed, and operated on a digital data platform, connected and synchronized with the national database system, databases of Ministries, central authorities, international organizations, and other relevant organizations. Tax administration authorities have the right to collect, access, use, and procure commercial databases available on the market in accordance with the law.

3. The Minister of Finance shall stipulate technical standards and build information technology infrastructure to serve the connection, exchange of information, and data sharing with relevant parties as prescribed by law. Ministries, ministerial-level agencies, government agencies, local authorities, and related units are responsible for building and implementing information technology systems that meet the requirements of connection and information exchange through the national integration and data-sharing platform, ensuring the accuracy, completeness, and timeliness of the data provided.

4. The tax administration authorities use the Tax Administration Information System to automatically issue documents, notifications, and tax administrative decisions based on professional processes, administration criteria, and data available in the system. Automatically issued tax documents, notifications, and administrative decisions shall be signed with the tax administration authority’s digital signature and hold the same legal validity as physical documents. The processing shall be recorded and stored in the Tax Administration Information System, allowing taxpayers to look up petitions, provide feedback, and request clarification of related information.

Article 36. Ensuring information security and information technology risk management

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2. Ministries, ministerial agencies, Governmental agencies, local governments, relevant units and tax administration authorities have the responsibility to:

a) Ensure safety, cybersecurity, and confidentiality of taxpayer information throughout the process of building, deploying, and operating the Tax Administration Information System;

b) Implement information technology risk management in tax administration;

c) Make sure the fulfillment of taxpayers’ tax obligations is not interrupted in the event of technical problems.

3. In case of technical problems in the Tax Administration Information System during taxpayers’ electronic transactions that prevent them from fulfilling their tax obligations by the prescribed deadline, taxpayers will not incur administrative penalties, late payment interest, and the interruption period shall be excluded from the tax authority’s processing time for tax dossiers.

4. The Government of Vietnam shall elaborate this Article.

Chapter VI

RIGHTS, OBLIGATIONS, DUTIES AND ENTITLEMENTS OF RELEVANT PARTIES IN TAX ADMINISTRATION

Article 37. Rights and obligations of taxpayers

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a) Receive assistance and guidance when paying tax; provide information and/or materials to fulfill tax obligations and exercise tax rights.

b) Look up, access, print and use electronic records that taxpayers have sent to the Tax Administration Information System as prescribed in this Law and e-transaction laws; request tax-withholding organizations to provide electronic withholding records;

c) Sign contracts with tax agents and customs brokerage agents for tax and customs services; authorize others to declare and pay tax on their behalf in accordance with tax laws, tax administration laws and customs laws;

d) Be prioritized in accordance with tax laws and customs laws if qualified;

dd) Look up their taxpayer status, receive notifications of tax debts via electronic transaction accounts provided by tax administration authorities;

e) Receive notifications, decisions, records, conclusions related to tax obligations from competent authorities upon inspections and audits;

g) Receive explanation for calculation of tax, other amounts, tax liability imposition, tax enforcement measures; have the opinions and explanation recorded; know the time limit for processing tax refund claims, tax amount ineligible for refund and legal basis therefor;

h) Be exempted from submission of documents and information already available in tax dossiers being held by tax administration authorities, unless there are changes or it is requested by tax administration authorities to serve tax inspections;

i) Request confirmation of fulfillment of tax obligations;

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l) File complaints, initiate legal proceedings against administrative decisions and/or actions related to their legitimate rights and interests;

m) Report violations committed by tax officials, other organizations and individuals in accordance with provisions on denunciation;

n) Receive compensation for damage caused by tax administration authorities and/or tax officials in accordance with regulations of law on State compensation liability;

o) Be exempted from administrative penalties for tax administration-related offences, exemption from late payment interest for cases where taxpayers comply with guidelines and handing decisions of tax authorities and/or state authorities on determination of their tax obligations;

p) Request assessment of exports and imports related to tax obligations;

q) Request enquiries and rectification of proofs of payment to state budget or data provided by tax administration authorities;

r) When the tax administration authority conducts a tax inspection, the taxpayer is entitled to refuse to undergo an on-site inspection if there is no on-site inspection decision issued by a competent authority; refuse to undergo tax inspection at the tax authority's premises if the tax authority has no request for explanation or supplementation of information or documents; refuse to provide information and documents not related to the inspection or that are state secrets, unless otherwise prescribed by law; provide explanation for issues related to the inspection and have their opinions recorded; file complaints and lawsuits, request compensation for damage as prescribed by law; denounce violations of law committed during tax inspections; exercise other rights prescribed by regulations of law on specialized inspections.

2. Taxpayers have the obligations to:

a) Apply for taxpayer registration and use TINs as prescribed by law;

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c) Fully and punctually pay tax, other amounts, late payment interest and fines. If the paid amount has been issued with a transaction identification number by the tax administration authority, the taxpayer shall make the payment using such transaction identification number;

d) Comply with regulations of law on accounting, statistics, invoices and records;

dd) Truthfully and fully record the taxable activities, tax deductions, and transactions subject to tax declaration;

e) Issue and provide invoices and records for buyers with the correct quantity, type and actual payment amounts when selling goods and/or providing services as prescribed by law;

g) Fully, accurately provide information and documents related to tax calculation, whether in physical or electronic forms; provide information for tax administration authorities for exchange with foreign tax administration authorities under international treaties and agreements to which the Socialist Republic of Vietnam is a signatory or member; explain the calculation of tax and other amounts; declare and pay tax and other amounts as requested by tax administration authorities;

h) Comply with decisions, notifications and requests of tax administration authorities, tax administration officials as prescribed by law;

i) Take responsibility for the fulfillment of tax obligations as prescribed by law, even if the taxpayer's legal representative or authorized representative fails to properly follow tax-related procedures;

k) Operate technical infrastructure for electronic transactions and transmission of information about tax obligations to tax administration authorities;

l) Only use goods and services granted tax exemption or tax cancellation for declared purposes; pay tax and other amounts if these goods and services are repurposed;

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n) Taxpayers that are social enterprises shall fully and accurately declare revenues from cooperation, sponsorship and economic contracts with foreign organizations and individuals used for social and environmental purposes in accordance with tax laws and relevant laws;

o) Taxpayers shall pay the tax imposed by tax authorities under tax decisions, even if they do not concur with it, in which case they may request explanation from the tax authority or file a complaint or lawsuit against the tax decisions. Taxpayers shall provide documents to support their complaints or lawsuits;

p) During tax inspections by tax administration authorities, taxpayers shall comply with on-site tax inspection decisions issued by tax administration authorities; comply with tax authorities' requests for explanation, supplementation of information and documents; promptly, fully and accurately provide information and documents related to tax inspection contents; sign tax inspection records by the deadlines prescribed by law; comply with conclusions and subsequent tax inspection-related decisions.

3. The Minister of Finance shall specify procedures for enquiring, adjusting information, confirming fulfillment of tax obligations as requested by taxpayers.

Article 38. Duties and entitlements of tax administration authorities and tax administration officials

1. Duties of tax administration authorities and tax administration officials:

a) Organize collection of taxes as prescribed by tax laws, late payment interest and fines in accordance with regulations of law on tax administration and administrative penalties;

b) Organize collection of other amounts, including: fees and charges prescribed by the Law on Fees and Charges; land levies; land rents; charges for granting rights to mineral extraction, water resource extraction; charges for use of sea areas; amounts collected from conversion of enterprises, public service providers; amounts collected from transfer of capital, right to buy shares, rights to contribute state capital to enterprises; post-tax profit after contribution to various funds of wholly state-owned enterprises, dividends and distributable profits on state capital in enterprises as per regulations; other amounts payable to state budget as prescribed by law.

Regarding fees and charges not directly collected by tax administration authorities, the agencies and organizations assigned to collect fees and charges as prescribed in the Law on Fees and Charges shall collect them in accordance with Clause 7 Article 39 of this Law.

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c) Disseminate and provide guidelines on tax regulations for taxpayers; publish administrative tax procedures, programs for voluntary compliance encouragement, preferential treatments at public administration service centers of provinces and communes, on the Tax Administration Information System and through mass media; apply digital technology to improve the effectiveness of supporting taxpayers in declaring, reporting, fulfilling tax obligations, and improving compliance with tax laws;

d) Provide and share taxpayer information to serve tax administration as per regulations;

dd) Confirm fulfillment of tax obligations; handle inquiries, corrections of information in accordance with the procedures prescribed by law. Confirm completion of any electronic transactions conducted by taxpayers;

e) Provide information on the status of taxpayers’ fulfillment of tax obligations (including overpaid tax and other amounts), notify outstanding tax debts via taxpayers' electronic transaction accounts;

g) Recompense taxpayers in accordance with provisions on the State’s compensation responsibilities for any damage caused illegally;

h) Carry out tax appraisal at the request of competent state authorities to determine tax obligations;

i) Develop and operate electronic information systems, apply information technology and digital transformation to tax administration; ensure data security and compatibility with systems of relevant state authorities;

k) Carry out bookkeeping of tax, other amounts, late payment interest, fines that must be collected, have been collected, are exempted, reduced, cancelled or refunded by tax administration authorities in accordance with accounting laws and state budget laws;

l) Organize announcement of tax statistics as prescribed by law;

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n) Tax administration officials have the responsibility to process tax dossiers on the basis of documents, instruments and information provided by taxpayers, databases of tax authorities, taxpayer-related information provided by competent authorities, and outcomes of the implementation of risk management measures in tax administration within the ambit of their responsibilities and duties, ensuring strict compliance with regulations of law on tax administration and other relevant tax-related laws, are not responsible for the contents of documents or materials in tax dossiers that have previously been approved, appraised, or resolved by other competent agencies or persons;

o) The tax administration authorities shall assist taxpayers having difficulties following tax procedures.

2. Powers of tax administration authorities:

a) Request taxpayers to provide information and documents related to tax obligations, including information about investment, ownership, bank accounts, finance, and explanations related to tax declaration, calculation, and payment; request relevant organizations and individuals to provide information and documents serving tax administration; exchange information with foreign tax authorities under international treaties or tax agreements and cooperate in fulfilling tax obligations; purchase and use domestic and foreign information and data for tax administration; use information from national databases and specialized databases to carry out tax administration and handle administrative procedures;

b) Conduct tax inspections; impose tax liability; enforce tax decisions; impose administrative penalties and publicly disclose violations through mass media; apply preventive measures and ensure enforcement of penalties in accordance with the law, including requesting business suspension, requesting business registration authorities to suspend changes to registration details of enterprises, cooperatives, cooperative unions, partnerships, household business while their tax offences are being handled; authorize organizations and individuals to collect tax as prescribed by the Minister of Finance.

3. The Government of Vietnam shall elaborate d Clause 1 of this Article.

Article 39. Duties, responsibilities and powers of state authorities, inspecting and supervising authorities, Vietnamese Fatherland Front, socio-political-professional organizations, social organizations, social-professional organizations in tax administration

1. Duties and powers of the Government of Vietnam:

a) Unifying state management of tax administration, ensuring close cooperation between regulatory bodies and local governments in tax administration;

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c) Reporting the state of tax administration to the National Assembly, the Standing Committee of the National Assembly and the President of Vietnam upon request.

2. The Ministry of Finance shall assist the Government of Vietnam in unifying state management of tax administration.

3. Responsibilities of Ministries, ministerial agencies, governmental agencies:

a) Cooperate with the Ministry of Finance in implementing tax policies, tax administration, digital transformation, sharing information and data to prevent tax evasion, tax fraud, and revenue loss in business activities on digital platforms, e-commerce, cross-border services, new business models, and other business sectors;

b) Establish connection and share information electronically with tax administration authorities to serve tax administration.

4. The People’s Councils of all levels shall, within their jurisdiction, establish annual state budget revenue targets and supervise the implementation of tax regulations in their administrative divisions.

5. The People’s Committees of all levels =, within their jurisdiction, have the following duties:

a) Directing relevant local agencies to cooperate with tax authorities in making budget estimates and organizing the collection of tax and other amounts payable to the state budget in their administrative divisions; carry out asset distraint and auction of assets of taxpayers subject to tax enforcement by distraint and auction of assets;

b) Cooperating with the Ministry of Finance, tax administration authorities and other competent authorities in managing and implementing tax regulations;

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d) Collect fees, charges and other amounts payable to the People’s Committees and not collected by tax administration authorities.

6. State authorities and organizations assigned to collect other amounts shall organize the collection in accordance with specialized laws, and may apply regulations of law on late payment interest and handling of overpaid amounts under this Law; propose implementation of enforcement measures specified in Points c, d, h Clause 1 Article 49 of this Law to competent state authorities, including:

a) Fines for tax administrative offences under regulations of law on administrative penalties.

b) Amounts payable to the state budget under regulations of law on management, use of public property collected from the management and use of public property for business operation, lease, joint venture, association, settlement of public property after payment of tax, fee and charges;

c) Charges for granting rights to use radio frequencies;

d) Foreign aids;

dd) Late payment interest on the amounts specified in this Clause;

e) Other amounts prescribed by law.

7. State authorities and organizations assigned to collect other fees and charges shall organize the collection in accordance with the Law on Fees and Charges, and may apply regulations of law on late payment interest and handling of overpaid amounts under this Law; propose implementation of enforcement measures specified in Points c, d, h Clause 1 Article 49 of this Law to competent state authorities.

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a) Issuing authorities of certificates and licenses must provide information on the contents of investment registration certificates, enterprise registration certificates, cooperative registration certificates, partnership registration certificates, household business registration certificates, ownership information, practicing licenses, establishment and operation licenses, certificates of changes in business registration contents of organizations and individuals, and other information as requested by tax administration authorities;

b) State Treasury shall provide information on tax amounts, other amounts, late payment interest, and fines paid by and refunded to taxpayers;

c) Land and housing authorities shall provide information about use of land and ownership of houses of organizations, households, household businesses and individual businesses;

d) Police authorities shall provide and exchanges information about tax offences with signs of criminal offences; information about entry and exit, registration and management of vehicles of taxpayers;

dd) Trade authorities shall provide information about policies on management of exports, imports and transited goods of Vietnam and other countries; market surveillance information;

e) Courts shall provide and exchange information on settlement of bankruptcy, rehabilitation, persons declared dead, missing or legally incapacitated, cancellation of decisions on declaration of dead, missing or legally incapacitated persons, and information on inheritance under civil law;

g) State authorities shall provide complete, timely, and accurate information as requested by the tax authorities to implement international agreements or treaties on taxation to which the Socialist Republic of Vietnam is a member or signatory.

9. Duties and powers of the State Audit Office:

a) Conducting audits on operations of tax administration authorities in accordance with state audit laws, tax laws and other relevant laws;

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c) In cases where the State Audit Office directly conducts an audit at a tax administration authority instead of on a taxpayer, and makes a request regarding tax obligations and other liabilities to state budget of the taxpayer, the State Audit Office must specify the taxpayer's tax administration-related offences and send a copied excerpt containing the request to the taxpayer. The tax administration authority shall be responsible for organizing the fulfillment of the request of the State Audit Office. If the taxpayer does not concur with the stated tax obligations and liabilities, they may file a request for the tax administration authority and the State Audit Office to review their tax obligations and liabilities, in which case the State Audit Office shall take charge and cooperate with the tax authority in determining the taxpayer’s correct tax obligations and other liabilities, and be held responsible as prescribed by law.

10. Duties and powers of the inspection authorities:

a) Inspection authorities shall conduct inspections of operations of tax administration authorities in accordance with inspection laws, tax laws and other relevant laws;

b) In cases where the inspection authority directly conduct an inspection of a taxpayer as prescribed in the Law on Inspection and makes a conclusion regarding tax obligations and other liabilities to state budget of the taxpayer, the inspection authority must specify the taxpayer's tax administration-related offences and send the inspection record, conclusion or post-inspection settlement decision to the taxpayer, and the taxpayer shall be responsible for fulfilling the request therein. The tax administration authority shall impose administrative penalties according to the document prepared and sent to the tax administration authority in accordance with the Law on Handling of Administrative Violations and this Law. If the taxpayer does not concur with the inspection authority's request or decision, they may file a complaint against it;

c) In cases where the inspection authority directly conducts an inspection at a tax administration authority instead of a taxpayer and makes a conclusion regarding tax obligations and other liabilities to state budget of the taxpayer, the inspection authority must specify the taxpayer's tax administration-related offences and send a copied excerpt containing the conclusion or decision to the taxpayer. The tax administration authority shall be responsible for organizing the implementation of the inspection authority's conclusion or decision. In case the taxpayer does not concur with the stated tax obligations or other liabilities, they may file a request for the tax administration authority and the inspection authority to review their tax obligations and other liabilities, in which case the inspection authority shall take charge and cooperate with the tax administration authority in determining the taxpayer’s correct tax obligations and other liabilities, and be held responsible as prescribed by law.

11. Investigating authorities, Procuracies and Courts shall, within their jurisdiction, receive, process and handle crime reports and petitions to press charges, bring charges against, investigate, prosecute and conduct trials of tax-related crimes promptly and justly, as prescribed by law, and notify tax administration authorities of the results.

12. Duties and powers of state authorities with powers to inspect and supervise implementation of regulations of law on tax, fees and charges:

a) Organizing inspections and supervisions of compliance of tax administration authorities and organizations collecting fees and charges with regulations of law on tax, fees and charges;

b) Organize inspections and supervisions under periodic plans, ad hoc plans, master plans or thematic plans at the premises of inspecting authorities or the inspected or supervised entity;

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d) Request the inspected or supervised entity, relevant authorities, organizations and individuals to provide explanation and sufficient documents to serve the inspection or supervision, and take responsibility for the accuracy and truthfulness of the information provided.

13. Duties and powers of the Vietnamese Fatherland Front:

a) Spread propaganda, mobilize all people’s classes to strictly comply with tax laws;

b) Supervise and socially criticize taxation; report to and request state authorities to consider and resolve tax-related issues as prescribed by law.

14. Socio-political-professional organizations, social organizations and socio-professional organizations shall cooperate with tax administration authorities in spreading propaganda, disseminating and educating tax laws to their members, and provide information relevant to tax administration.

15. The Government of Vietnam shall elaborate this Article and the following contents: content, form, scope, and time limits for providing information, responsibilities and powers of the parties involved in sharing information and establishing connection serving tax administration.

Article 40. Duties, powers and responsibilities of other organizations and individuals in tax administration

1. Duties and powers of communication and press agencies:

a) Promote, disseminate tax policies and tax laws; praise compliant organizations and individuals and criticize tax offences;

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2. Duties and powers of credit institutions, foreign bank branches, providers of payment services, providers of payment intermediary services:

a) Cooperate with tax administration authorities and the State Treasury in collecting and refunding tax and other amounts electronically; process, compare and review electronic data about tax payment and tax refund; transmit and receive electronic records on tax payments, transfer of money to state budget, and fully and promptly send information to tax administration authorities as prescribed by law; do not cancel money transfer orders after tax payment information has been sent to tax administration authorities; assist taxpayers in paying tax electronically; protect the confidentiality of information of taxpayers and customs declarants as prescribed by law;

b) Periodically provide information on checking account numbers linked to taxpayers’ tax identification numbers when checking accounts are opened and closed at payment service providers permitted to open checking accounts;

c) Establish connection and share information related to transactions and other taxpayer information to serve tax administration; provide information on unusual transactions, and provide complete, timely, and accurate information at the request of tax authorities to implement international treaties or agreements on taxation to which the Socialist Republic of Vietnam is a member or signatory at the request of tax administration authorities;

d) Receive electronic decisions on tax enforcement by withdrawing money from accounts or freezing accounts of taxpayers subject to tax enforcement; withdraw money from taxpayers’ accounts to pay tax and other amounts, and freeze accounts of taxpayers subject to tax enforcement at the request of tax administration authorities;

dd) In cases where the taxpayer has guarantee for payment of tax, late payment interest, fines, and other amounts to the state budget under this Law but fail to pay on time, the guarantor must fully pay the tax, late payment interest, fines, and other amounts to state budget on behalf of the taxpayer within the scope of the guarantee contract/agreements/commitments, and within the guarantee period;

e) Payment service providers (excluding the State Bank of Vietnam) must provide information on imported goods pledged as collateral for loans at the request of customs authorities;

g) In cases where the secured party (excluding the State Bank of Vietnam) sells the collateral to settle debts under the law on handling secured assets and regulations of law on credit institutions, the secured party or the buyer must declare and fully pay taxes related to the collateral transaction on behalf of the guarantor.

If the collateral sold is imported goods eligible for tax exemption or non-imposition of tax, the seller of the collateral or the buyer must declare and fully pay taxes related to the collateral on behalf of the guarantor;

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i) Intermediary payment service providers shall cooperate with tax administration authorities in tax collection.

3. Duties, powers and responsibilities of other organizations and individuals:

a) Provide information related to identification of taxpayers and their tax obligations, and provide complete, timely, and accurate information at the request of tax administration authorities to implement international treaties or agreements on taxation to which the Socialist Republic of Vietnam is a member or signatory;

b) Cooperate with tax administration authorities in implementing decisions on administrative penalties for tax administration-related violations;

c) Report tax offences to tax administration authorities or competent authorities;

d) Request sellers and service providers to provide sales invoices and records with the correct quantity, type and value when purchasing goods and services.

dd) Authorized persons, guarantors, or those paying tax on behalf of taxpayers shall provide information on exports and imports for tax administration authorities as the basis for tax liability imposition under Article 25 of this Law;

e) Other organizations and individuals relevant to taxpayers shall provide information physically or electronically at the request of tax administration authorities to serve tax administration;

g) Organizations managing e-commerce platforms, organizations providing digital asset services, logistics service providers, international card organizations, foreign organizations providing payment services, intermediary payment services, or electronic transaction processing services for organizations and individuals in Vietnam shall provide information periodically or upon request for tax administration authorities;

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i) If the third party owes a due debt payable to the taxpayer or is holding the taxpayer’s money or assets, the third party shall provide information about such money or assets, and pay the tax debt in lieu of the taxpayer;

k) Agencies or organizations collecting proceeds from auctions shall provide information on the names, quantities, and values of goods that have been distrained and auctioned for customs authorities for tax liability imposition on imports that have not completed customs procedures but were distrained and auctioned by customs authorities for tax enforcement, and for goods eligible for tax exemption of non-imposition of tax that were distrained and auctioned under decisions of competent authorities or court judgments/decisions;

l) In cases where an auctioneering organization sells collateral to settle a taxpayer's obligations, and ownership or use rights of the collateralized assets have been transferred to the auctioneering organization, the auctioneering organization shall declare and pay tax, late payment interest, fines, and other amounts to the state budget arising from the collateralized assets. If the collateralized assets remain under the ownership or use rights of the taxpayer, the auctioneering organization shall withhold and pay tax and other amounts related to the collateralized assets on behalf of the taxpayer. The auctioneering organization shall declare and fully pay tax related to collateralized imports eligible for tax exemption of non-imposition of tax on behalf of the taxpayer.

4. In cases where the organizations specified at Points a, b, c, d, dd and e Clause 3 of this Article detect errors or mistakes that need to be corrected in the information exchanged between authorities, they shall send rectifying documents as per regulations.

5. Tax agents, household businesses and individual businesses providing tax-related services:

a) A tax agent is an enterprise that is established and operates as prescribed by law, has at least 02 persons qualified for tax counseling who work full-time at the enterprise to provide tax-related services for taxpayers under agreements;

b) Household businesses and individual businesses providing tax-related services are individuals qualified for tax counseling who provide tax-related services for taxpayers under agreements;

c) Services provided by tax agents, household businesses and individual businesses providing tax-related services for taxpayers under contracts include: tax registration, declaration, payment, settlement, application for tax exemption, reduction, refund, and other tax-related procedures on behalf of taxpayers; tax counseling; accounting services prescribed by accounting laws;

d) Tax agents, household businesses and individual businesses providing tax-related services have the following rights and obligations: comply with this Law, tax laws and other relevant laws when providing tax-related services; take legal responsibility and be accountable to taxpayers for the services provided.

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7. The Minister of Finance shall provide for management of provision of tax-related services.

8. The Government of Vietnam shall elaborate the following contents: duties and entitlements of communication and press agencies, credit institutions, foreign bank branches, providers of payment services, providers of payment intermediary services, providers of online payment services, contents, methods and time limits for establishing connection and providing information serving tax administration prescribed in this Article; standards for provision of tax-related services.

Chapter VII

COMPLAINTS, DENUNCIATIONS, DISPUTE SETTLEMENT

Article 41. Tax-related complaints, denunciations, dispute settlement

1. Taxpayers, organizations and individuals are entitled to file complaints to competent authorities against administrative decisions, administrative actions of tax administration authorities, competent persons of tax administration authorities if there are grounds to believe that such decisions or actions are unlawful and directly infringe upon their lawful rights and interests. Complainants are entitled to be informed of the procedures for complaint resolution on the Tax Administration Information System as prescribed by law.

2. Individuals are entitled to denounce tax offences committed by taxpayers, tax officials, other organizations and individuals.

3. Complaints and denunciations shall be settled in accordance with regulations of law on complaints and denunciations.

4. Tax disputes between taxpayers that are foreign or Vietnamese organizations or individuals and Vietnamese tax administration authorities over tax obligations arising in Vietnam or abroad may be settled through:

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b) Proceedings as prescribed by regulations of administrative proceedings;

c) Dispute settlement mechanisms specified in the contracts, agreements and guarantee commitments of the Government of Vietnam, international treaties on taxation and other treaties to which the Socialist Republic of Vietnam is a member or signatory (if any).

Article 42. Responsibilities and powers of tax administration authorities in settlement of tax-related complaints

1. The tax administration authority that receives the complaint is entitled to request the plaintiff to provide supporting documents. If the plaintiff fails to provide such documents, the tax authority is entitled to reject the complaint.

2. The tax administration authority shall return the incorrectly collected tax, other amounts, late payment interest and fine to the taxpayer or the third party within 15 days from the receipt of the handling decision from the complaint-settling authority.

3. If the case is complicated, the head of the complaint-settling authority shall consult with relevant organizations, in which case a counseling council shall be established. The counseling council shall vote under the majority rule. The voting result is the basis for the head of the tax authority to settle the complaint. The head of the tax authority shall make the final decision and take responsibility for such decision.

Article 43. Filing lawsuits

Lawsuits against administrative decisions and administrative actions of tax administration authorities, competent persons of tax administration authorities, and state authorities shall be filed in accordance with regulations of law on administrative proceedings.

Chapter VIII

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Section 1. Administrative penalties for tax administration-related offences

Article 44. Rules for imposition of administrative penalties for tax administration-related offences

1. Administrative penalties for tax administration-related offences shall be imposed in accordance with regulations of law on tax administration and administrative penalties.

2. Exemption of administrative penalties for tax administration-related offences:

a) The taxpayer had made an incorrect declaration as prescribed in Clause 2 Article 45 of this Law but subsequently made a supplementary declaration and voluntarily paid the tax arrears before the tax authority announced the tax inspection decision or another competent authority announced the decision to carry out an inspection at the taxpayer's premises, before the taxpayer discovered the incorrect declaration without tax inspection at the taxpayer's premises, or before incorrect declaration was discovered by another competent authority; the individual who directly settled personal income tax submitted the personal income tax settlement dossier behind schedule but was entitled to a tax refund, and other cases in which administrative penalties are exempted prescribed in this Law, other relevant laws, and other cases prescribed by the Government of Vietnam;

b) The taxpayer had made an incorrect declaration as prescribed in Clause 3 Article 45 of this Law but subsequently made a supplementary declaration before the customs authority announced the physical inspection of the customs dossier while the goods were undergoing customs procedures; the taxpayer makes a supplementary declaration within 60 days from the day on which customs clearance is granted and before the date of issuance of the decision on inspection of goods granted customs clearance, post-customs clearance inspection, and other cases prescribed by the Government of Vietnam.

3. Imposition of fines for tax administration-related offences:

a) The fine for understatement of tax amount payable or overstatement of tax amount eligible for exemption, reduction, refund or cancellation in the cases specified in Point a Clause 3 Article 45 of this Law shall be 10% of the difference;

b) The fine for understatement of tax amount payable or overstatement of tax amount eligible for exemption, reduction, refund or cancellation in the cases specified in Clause 2, Point b and Point c Clause 3 Article 45 of this Law shall be 20% of the difference;

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4. The fine for a tax administration-related offence committed by an organization shall be twice the fine for the same offence committed by an individual, except in cases of understatement of tax amount payable and overstatement of tax amount eligible for exemption, reduction, refund, cancellation, and tax evasion, where the fines imposed shall be the same for organization and individuals.

5. In cases where the taxpayer is subject to tax liability imposition as prescribed in Article 24 and Article 25 of this Law, the offence, depending on its nature and seriousness, may incur the administrative penalties for tax administration-related offences prescribed in this Law.

6. Criminal laws shall apply if the tax administration-related offence is liable to criminal prosecution.

7. The prescriptive period for imposition of penalties for failure to properly follow tax procedures shall be 02 years. The prescriptive period for imposition of penalties for tax evasion that is not liable to criminal prosecution, understatement of tax amount payable or overstatement of tax amount eligible for exemption, reduction, refund, or cancellation shall be 05 years. The prescriptive period shall be reckoned in accordance with regulations of law on administrative penalties.

8. After the aforementioned prescriptive period expires, the taxpayer will not incur penalties but still has to fully pay the outstanding tax, evaded tax, incorrectly reduced, exempted or refunded tax plus (+) late payment interest that have accrued over 10 years before the offence is discovered. In case the taxpayer is not registered, the outstanding tax, evaded tax, late payment interest that have accrued before the offence is discovered shall be fully paid.

9. In cases where the taxpayer incurs a fine for tax administration-related offences and suffers damage due to force majeure events prescribed in Clause 21 Article 4 of this Law, the fine will be exempted. The total amount of fine exempted must not exceed the damage to property or goods. Fines for tax administration-related offences shall not be exempted if the decision on administrative penalties for tax administration-related offences issued by the tax administration authority or competent authority has been implemented.

10. The Government of Vietnam shall elaborate this Article.

Article 45. Tax administration-related offences

1. Offences against regulations on tax procedures, electronic records and invoices.

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3. Understatement of tax amount payable or overstatement of tax amount eligible for tax exemption, reduction, refund on exports and imports other than the cases prescribed in Point e, Point g Clause 4 of this Article, Point b Clause 2 Article 44 of this Law. For this offence, in addition to fully pay tax and late payment interest, the taxpayer will also incur administrative penalties for tax administration-related offences in the following cases:

a) The taxpayer realizes the mistakes and makes a supplementary declaration after the customs authority has announced the physical inspection of customs documents of the goods undergoing customs procedures, or after 60 days from the customs clearance date and before the customs authority issues the decision on post-clearance inspection or inspection of goods granted customs clearance;

b) The mistakes are discovered by the customs authority while the goods are undergoing customs procedures, during post-customs clearance inspection, during inspection of goods that have been granted customs clearance, and the violator has voluntarily paid the tax amount payable in full;

c) It is not the cases specified in Point a and Point b of this Clause and the taxpayer has voluntarily paid the tax amount payable in full.

4. Acts of tax evasion:

a) Failure to submit the application for taxpayer registration; failure to submit the tax declaration dossier or to submit the tax declaration within 90 days from the deadline or extended deadline for submission prescribed in this Law, resulting in understatement of tax amount payable or overstatement of tax amount eligible for exemption, reduction or refund;

b) Failure to recognize, record the revenues relevant to calculation of tax amount payable in the accounting books;

c) Failure to issue invoices and failure to declare tax when selling goods/services as prescribed by law; write lower prices on the sale invoices than the actual prices of the goods/services sold for tax declaration purposes;

d) Use of illegal invoices and records, or illegal use of invoices and records for purchased goods and services in order to decrease tax amount payable or increase the tax amount eligible for exemption, reduction, deduction, refund or cancellation;

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e) Incorrect declaration of exports or imports without voluntary payment of tax amount payable as per regulations;

g) Deliberate omission or incorrect declaration of taxes on exports or imports;

h) Collaboration with the consignor in tax evasion;

i) Repurposing of tax-free goods without informing the tax administration authority.

k) Carrying on business operation during the suspension period without informing the tax administration authority;

l) The taxpayer shall incur penalties for violations of tax procedures instead of penalties for tax evasion in the following cases: The taxpayer fails to submit the application for taxpayer registration; fails to submit the tax declaration dossier or submits the tax declaration after 90 days from the submission deadline or extended deadline without incurring tax; submits the tax declaration dossier after 90 days from the submission deadline or extended deadline and has fully paid tax and late payment interest before the tax authority announces the tax inspection decision or issues the notice of late submission of tax declaration dossier.

5. The Government of Vietnam shall elaborate this Article.

Article 46. Actions against violations committed by credit institutions, foreign bank branches, providers of payment services, providers of payment intermediary services, tax payment guarantors, organizations and individuals relevant to tax administration

1. Credit institutions, foreign bank branches, providers of payment services, providers of payment intermediary services that fail to deduct and transfer outstanding tax amount from taxpayers' accounts to state budget as requested by tax administration authorities shall incur a fine equal to that amount, unless the taxpayer's account balance is empty or insufficient.

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3. The relevant organizations and individuals mentioned in Clause 4 Article 2 of this Law shall face administrative penalties or criminal prosecution, nature and severity of the violations, if they collaborate with taxpayers in tax evasion or refuse to implement tax enforcement decisions.

4. The relevant organizations and individuals mentioned in Clause 4 Article 2 of this Law shall face administrative penalties or criminal prosecution, nature and severity of the violations, if they fail to fulfill their obligations prescribed by this Law.

5. The Government of Vietnam shall elaborate this Article.

Article 47. Powers to impose administrative penalties for tax administration-related offences

1. The powers to impose administrative penalties for tax administration-related offences shall comply with regulations of law on tax administration and administrative penalties.

2. Heads of tax administration authorities have the powers to impose penalties for the offences specified in Articles 45 and 46 of this Law.

Section 2. TAX ENFORCEMENT

Article 48. Cases of tax enforcement

1. The taxpayer’s tax has been overdue for more than 90 days.

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3. The taxpayer has a tax debt but is not operating at the registered address, or attempts to liquidate assets.

4. The taxpayer fails to implement the tax decision by the deadline written therein, unless it is deferred.

5. The taxpayer incurred an administrative penalty for failure to comply with the tax inspection decision but continues to refuse to comply with the tax inspection decision.

6. Tax shall not be enforced against tax debts exempted from late payment interest and tax debts permitted to be paid by instalment for 12 months from the day on which the competent authority issues the document permitting payment of tax debt by instalments and during the effective period of the guarantee letter. Payment of tax debt by instalments shall be considered by heads of tax administration authorities on the basis of taxpayers' request and credit institutions' guarantee.

7. Tax shall not be enforced against taxpayers that owe customs fees or fees for transit of goods or vehicles.

8. Tax authorities shall not enforce payment of tax debts that are being offset against refundable tax amounts by tax authorities.

9. Heads of tax administration authorities shall decide tax enforcement on a case-by-case basis.

10. The Government of Vietnam shall elaborate this Article.

Article 49. Tax enforcement measures

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a) Withdraw money from the taxpayer's account at the State Treasury, commercial bank or credit institution; freezing accounts;

d) Deduct money from the taxpayer’ salary or income;

c) Suspend customs procedures for exports or imports;

d) Suspend use of invoices;

dd) Confiscate the taxpayer’s money and assets that are being held by a third party;

e) Seize the taxpayer’s assets and sell them at auction in accordance with law;

g) File a petition for bankruptcy of the taxpayer;

h) Revoke the taxpayer's business/enterprise/ cooperative/artel/household business/ registration certificate, establishment and operation license, practicing license, branch/representative office/business location registration certificate, e-commerce platform-based business registration certificate/license.

2. The tax enforcement measures prescribed in Clause 1 of this Article will be terminated when:

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b) The tax administration authority or a competent authority issues a document to grant tax exemption, tax reduction, tax cancellation, tax deferral, tax payment by instalment, or exemption of late payment interest;

c) A competent authority issues a written request for invalidation of the enforcement decision;

d) The taxpayer has complied with the tax inspection decision in the case prescribed in Clause 5 Article 48 of this Law.

3. The tax enforcement decision shall be sent to the taxpayer, relevant organizations and individual. The decision may be sent electronically if feasible.

4. When filing a petition for bankruptcy of a taxpayer, the tax administration authority is not required to pay fees and advance bankruptcy expenses.

5. The Government of Vietnam shall elaborate this Article and procedures for enforcement.

Article 50. Powers to decide tax enforcement

1. Heads of tax administration authorities have the powers to:

a) Issue decisions on tax enforcement using the measures prescribed in Points a, b, c, d and dd Clause 1 Article 49 of this Law;

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c) Request competent authorities to implement the measures prescribed in Point h Clause 1 Article 49 of this Law.

2. Presidents of the People’s Committees at all levels have the powers to issue decisions on tax enforcement by seizing and selling assets at auction at the request of tax administration authorities.

3. The Government of Vietnam shall elaborate this Article.

Chapter IX

IMPLEMENTATION CLAUSES

Article 51. Addition of Article 70a after Article 70 of the Law on Accounting No. 88/2015/QH13, amended by Law No. 38/2019/QH14 and Law No. 56/2024/QH15

Article 70a below is added after Article 70:

“Article 70a. Provision of accounting services by tax agents

A tax agent may provide accounting services to microenterprises, household businesses and individual businesses if at least one of their employees has the accountant certificate.”.

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1. This Law enters into force from July 01, 2025, except for the cases specified in Clause 2 of this Article.

2. Provisions of Article 13 and regulations on use of electronic invoices by household businesses and individual businesses in Article 26 of this Law are effective from January 01, 2026.

3. The Law on Tax administration No. 38/2019/QH14, which was amended by Law No. 56/2024/QH15 (hereinafter referred to as "the Law on Tax Administration No. 38/2019/QH14) ceases to be effective from the effective date of this Law, except Clause 1 and Clause 3 Article 53 of this Law; Article 51 of the Law on Tax Administration No. 38/2019/QH14 ceases to be effective from January 01, 2026.

4. Tax authorities shall organize the development, upgrade and completion of the information system serving electronic transactions in tax administration. The conversion to 100% electronic transactions in tax administration shall follow the road map of the Minister of Finance, ensuring completion before January 01, 2027.

5. The Government shall elaborate the assigned Articles and Clauses of this Law, provide guidelines for implementation of this Law within its jurisdiction; promulgate regulations on tax administration of related-party transactions of related enterprises; promulgate regulations on administrative penalties for fee- and charge-related offences in tax administration.

Article 53. Transition clauses

1. Tax exemption, reduction, cancellation granted in accordance with applicable laws before July 01, 2026 shall continue to be handled in accordance with the Law on Tax Administration No. 38/2019/QH14.

2. Tax debts that are owed by the end of June 30, 2026 shall be handled in accordance with this Law.

3. Ongoing tax inspections under inspection decisions issued before the effective date of this Law, for which conclusion or handling decision has not been issued, shall be carried on in accordance with the Law on Tax Administration No. 38/2019/QH14.

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CHAIRPERSON OF THE NATIONAL ASSEMBLY




Tran Thanh Man