CIRCULAR

ON TAX COMPLIANCE AND RISK MANAGEMENT

Pursuant to the Law on Tax Administration No. 108/2025/QH15;

Pursuant to Decree No. 252/2026/ND-CP of the Government elaborating certain articles and providing measures for the organization and guidance on the implementation of the Law on Tax Administration;

Pursuant to Decree No. 254/2026/ND-CP of the Government elaborating certain articles and providing measures for the organization and guidance on the implementation of the Law on Tax Administration No. 108/2025/QH15 on e-invoices and electronic vouchers;

Pursuant to Decree No. 29/2025/ND-CP of the Government on the functions, tasks, powers and organizational structure of the Ministry of Finance, as amended by Decree No. 166/2025/ND-CP of the Government;

At the proposal of the Director of the Tax Department;

The Minister of Finance hereby promulgates a Circular on tax compliance and risk management.

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 GENERAL PROVISIONS

Article 1. Scope

This Circular provides for:

1. The collection, processing, management and use of information relating to taxpayers for tax compliance and risk management purposes.

2. The criteria for the assessment and classification of the risk level and the application of risk management in tax administration operations as prescribed in clause 5 of Article 33 of the Law on Tax Administration No. 108/2025/QH15.

3. The criteria for the assessment of taxpayers’ tax law compliance and tax compliance management activities as prescribed in clause 3 of Article 34 of the Law on Tax Administration No. 108/2025/QH15.

Article 2. Regulated entities

1. Taxpayers.

2. Tax authorities.

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4. Other state agencies, organizations and individuals related to tax administration activities.

Article 3. Definitions

For the purposes of this Circular, the following terms shall be construed as follows:

1. Tax compliance and risk management information means information on taxes, information related to taxes and information related to taxpayers collected and processed by tax authorities for tax compliance and risk management purposes.

2. Tax law compliance level means the result of the tax authority’s assessment and classification of the full, timely and proper fulfillment of tax obligations under tax law by a taxpayer throughout the processes of registration, declaration, tax payment, tax reporting and provision of information to the tax authority.

3. Criteria for the assessment and classification of the tax law compliance level means the system of standards and indicators used to assess and classify the tax law compliance level of taxpayers.

4. Indicators of the criteria for the assessment and classification of the tax law compliance level means the information indicators bearing specific values of the criteria for the assessment and classification of taxpayers’ tax law compliance.

5. Assessment and classification of the tax law compliance level means the analysis of information and data to determine the degree of tax law compliance of a taxpayer and to assign the taxpayer to different compliance groups.

6. Risk level means the measure reflecting the likelihood of occurrence and the degree of impact of a taxpayer’s tax law non-compliant conduct on the fulfillment of tax obligations and the tax authority’s tax administration work.

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8. Indicators of the criteria for the assessment and classification of the risk level means the information indicators bearing specific values of the criteria for the assessment and classification of the risk level.

9. Assessment and classification of the risk level of taxpayers means the analysis, measurement and determination of the potential level of tax law non-compliant conduct and the assignment of taxpayers to different risk groups.

10. Risk indicator means a factor bearing information value that reflects the potential for law-violating conduct.

11. Indicator of tax law violations means a factor bearing information value that serves as the basis for identifying tax law-violating conduct.

12. Targeted monitoring means the application by the tax authority of tax administration operational measures to closely monitor and control the activities of taxpayers that show high-risk indicators or indicators of tax law violations over a given period of time.

13. Tax compliance and risk management subsystem means the specialized functional layer within the tax sector’s tax governance system, developed to serve the collection, processing and analysis of information; the assessment and classification of taxpayers’ tax law compliance level and risk level; and to support the proposal, coordination, monitoring, tracing and feedback of the results of the application of tax administration measures in accordance with law.

The tax compliance and risk management subsystem comprises functions, data, taxpayers’ electronic files, compliance cases and records, risk files, the risk register, sets of criteria and indicators, business rules, analytical models, warning and forecasting tools and decision-support tools; it is managed and operated on a centralized basis with delegated access and use rights in accordance with the functions, duties and authority of tax authorities at all levels.

The tax compliance and risk management subsystem does not replace the decision-making responsibility of the competent tax authority or tax officer; the use of analytical results, warnings and proposals of the subsystem must ensure objectivity, transparency, traceability, accountability, confidentiality of taxpayer information, protection of personal data, information system security and compliance with relevant laws.

14. Classification using the machine learning method means running computational and statistical algorithms on computers to identify models, functions and indicators that support the classification and forecasting of risk levels.

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16. Scoring and score-based classification method means the method of assessing taxpayers on the basis of the scores of criteria and indicators relating to their operational track record and tax law compliance.

17. Risk register means the database storing information on risks in the tax compliance and risk management subsystem, which allows retrieval of definitions, the severity of consequences, the number and types of taxpayers associated with a given risk; assessment reports, scoring criteria and rules, together with appropriate handling plans and measures commensurate with the scale and risk ranking of each risk following analysis.

Article 4. Principles of tax compliance and risk management

1. The application of tax compliance and risk management must ensure objectivity, transparency and conformity with law, and must be non-discriminatory; it shall be carried out with a view to enhancing the effectiveness and efficiency of tax administration, encouraging and facilitating taxpayers’ voluntary compliance with tax law, while deterring, detecting and promptly handling tax law violations.

2. Tax compliance and risk management must be carried out on the basis of objective, comprehensive and regularly updated data analysis; applying management measures suited to the characteristics, tax law compliance level and risk level of each group and each taxpayer; and prioritizing the application of modern information technology and automation in data collection, processing, assessment and classification.

3. Information serving tax compliance and risk management shall be collected from information sources inside and outside the tax authority, including information from abroad in accordance with law and the provisions of Article 6 of this Circular; managed through the tax sector’s tax governance system; and processed, shared and provided to tax authorities at all levels and relevant state agencies for state management purposes in accordance with law.

4. The assessment and classification of taxpayers’ tax law compliance level and risk level shall be conducted automatically and periodically, using one or a combination of the methods prescribed in this Circular, on the basis of tax administration operational processes and measures, the system of criteria and the database on taxpayers.

5. Where the tax compliance and risk management subsystem experiences a technical failure or does not yet meet the requirements for the application of tax compliance and risk management, the process shall be carried out manually on the basis of written approval by the competent person in accordance with the Law on Tax Administration No. 108/2025/QH15 and guidance documents.

6. Where there are changes in information that alter the results of the assessment and classification of a taxpayer’s tax law compliance level and risk level and the application system has not yet automatically updated, the adjustment shall be carried out manually by a tax officer following approval by the competent person.

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a) Decide on examination, monitoring and the application of appropriate tax administration operational measures;

b) Develop plans and measures to improve overall compliance levels, commensurate with available resources, on the basis of analysis of the conduct, causes and scale of each compliance level and risk level.

8. The results of the application of operational measures corresponding to each taxpayer’s tax law compliance level and risk level must be fully and accurately updated in the tax administration support applications or the tax compliance and risk management subsystem of the tax authority for each specific case, as the basis for improving the mechanism and the assessment and classification of taxpayers’ tax law compliance level and risk level in subsequent periods.

9. Tax officers shall not bear personal liability for acts carried out in conformity with this Circular and guidelines on tax compliance and risk management in the performance of their duties.

Article 5. Assessment methods

The tax law compliance level and risk level of a taxpayer shall be determined using one or a combination of the following methods:

1. Scoring and score-based classification method.

2. Machine learning method.

3. Category-based ranking method.

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1. Tax compliance and risk management information.

Information serving tax compliance and risk management includes:

a) Information within the tax authority:

a.1) Information on tax registration; owners of taxpayers; labor registration and use; information on taxpayer status; number of changes to business registration and tax registration information; status of capital contributions by members; related-party capital contribution relationships; affiliated relationships; principal business lines;

a.2) Information on tax return files; tax payment; tax debts; tax incentives, exemptions and reductions; extension of tax payment deadlines; payment of tax in installments; tax refunds; registration, management and use of invoices and vouchers; information on complaints and denunciations; information on the results of inspections, examinations, audits and investigations and post-inspection, post-examination, post-audit and post-investigation handling; information on related-party transactions;

a.3) Other information.

b) Information collected from state agencies, organizations and responsible individuals:

b.1) Information on taxpayers collected from state agencies, organizations and related individuals in accordance with Decree No. 252/2026/ND-CP;

b.2) Information from abroad and international organizations provided pursuant to obligations under relevant international tax treaties to which the Socialist Republic of Vietnam is a party.

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2. Collection and processing of tax compliance and risk management information.

a) Sources of information collection:

a.1) From the tax authority’s internal information systems;

a.2) From coordinated information exchange with units under the Ministry of Finance and units under the Ministries, sector agencies and relevant agencies;

a.3) From coordinated information exchange with foreign tax authorities and competent authorities abroad in accordance with law;

a.4) Receipt of information provided by state agencies, organizations and individuals in accordance with law;

a.5) Information related to the operations of taxpayers collected in the course of tax administration;

a.6) Information from the results of surveys, assessments and public opinion surveys conducted by political organizations, socio-political organizations or reputable domestic and international organizations;

a.7) Purchase of information in accordance with the Law on Tax Administration No. 108/2025/QH15 and guidance documents;

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a.9) From other relevant information sources in accordance with law.

b) Forms of information collection:

b.1) Provision and exchange in the form of electronic data, electronic vouchers, emails, exchange through the Tax Department’s electronic information portal, the national public service portal; text messages and calls to telephone numbers officially announced by the tax authority;

b.2) Provision and exchange by written documents, telegrams, cables, fax and paper documents;

b.3) Direct exchange on the basis of written records of confirmation, with acknowledgment by the relevant parties; assignment of representatives to work, verify and collect information and documents; organization of conferences and other forms.

c) Processing of collected information:

c.1) Assessment of the relevance of the information to the purpose and needs of use; consideration of the reliability and accuracy of the information;

c.2) Classification, organization and storage of information from various sources by information group for retrieval and analysis;

c.3) Analysis of the information, consideration and identification of the elements constituting the content of the information for tax compliance and risk management purposes;

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Article 7. Operation of the tax compliance and risk management subsystem

1. The tax compliance and risk management subsystem is managed and operated on a centralized basis within the tax sector’s tax governance system; the Tax Department is the lead agency responsible for organizing the operation and delegating access and use rights to tax authorities at all levels in accordance with their respective functions, duties and authority.

The tax compliance and risk management subsystem connects, integrates with and shares data with other functional layers, subsystems, databases and operational applications of the tax sector in accordance with the technical architecture, standards, management and operation regulations and applicable law.

2. The tax compliance and risk management subsystem operates on the tax sector’s digital data platform, taxpayers’ electronic files, compliance cases and records, the risk register, sets of criteria and indicators, business rules, analytical models and other lawfully relevant data sources.

The receipt, updating, processing and utilization of data in the tax compliance and risk management subsystem shall be conducted in real-time, near-real-time, or on a periodic or batch basis suited to the nature of each data source, technical conditions, tax administration requirements and applicable law.

3. The tax compliance and risk management subsystem performs the following functions automatically or semi-automatically to serve tax compliance and risk management:

a) Receipt, collection, verification, standardization, reconciliation, consolidation, storage and retrieval of information and data for tax compliance and risk management purposes;

b) Recording, updating and monitoring events arising in the course of tax administration that are related to taxpayers’ tax law compliance level and risk level;

c) Creation, updating, management and lifecycle monitoring of taxpayers’ electronic files, compliance cases and records and risk files;

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dd) Detection and warning of risk indicators and indicators of tax law violations; analysis of trends, conduct, relationships, networks and latent risk patterns;

e) Proposal of treatment strategies, tax administration operational measures, intervention plans, monitoring or examination plans suited to the tax law compliance level, risk level and characteristics of each group and each taxpayer;

g) Monitoring, tracking, tracing, synthesis, assessment and feedback of the results of the application of tax administration measures for the purpose of updating criteria, indicators and analytical models and enhancing the effectiveness of tax compliance and risk management in subsequent periods.

4. The tax compliance and risk management subsystem applies data analytics technology, big data, machine learning, artificial intelligence (AI) and other appropriate technologies to support the processing, analysis, warning, forecasting and proposal of operational measures.

The analytical results, warnings, forecasts, scores, classifications or proposals of the tax compliance and risk management subsystem serve as a basis to support competent tax authorities and tax officers in the process of considering, selecting, deciding and organizing the implementation of tax administration measures in accordance with law; they do not replace the responsibility of competent tax authorities and tax officers in issuing administrative tax decisions or implementing tax administration operational measures.

The application of machine learning, artificial intelligence and analytical models in the tax compliance and risk management subsystem must comply with the principles of objectivity, transparency, controllability, traceability and accountability; and must be tested, assessed, monitored and updated in accordance with management requirements and applicable law.

5. The results of processing, analysis, assessment, classification and warnings of the tax compliance and risk management subsystem shall be accessed and used as follows:

a) For taxpayers: to support the provision of electronic tax services, early risk warnings, compliance recommendations, support for the review and rectification of errors and enhancement of voluntary tax law compliance;

b) For tax authorities and tax officers: to provide information, data, files, warnings, analytical results, classification results and proposals for operational measures to serve tax compliance and risk management, audit planning, targeted monitoring, tax debt management, invoice and voucher management, tax refunds and other tax administration operations in accordance with law;

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6. The Tax Department is responsible for issuing regulations, processes, standards and guidelines on the management, operation and use of the tax compliance and risk management subsystem; the management of data, taxpayers’ electronic files, compliance cases and records, the risk register, sets of criteria and indicators, business rules and analytical models; and delegated rights to access, retrieve, use and update information in the tax compliance and risk management subsystem.

The management, operation and use of the tax compliance and risk management subsystem must maintain information system security, cybersecurity, confidentiality of taxpayer information, protection of personal data, access log management, processing traceability, record retention, delineation of responsibilities and compliance with relevant laws.

Where the tax compliance and risk management subsystem experiences a technical failure, does not yet meet operational requirements or has not yet been integrated with necessary data sources, the Tax Department shall organize the implementation of temporary handling measures, including the use of temporary files/forms, recording the full grounds, substance, time and person responsible for the handling; the decision to apply temporary handling measures shall be approved by the competent person; after the tax compliance and risk management subsystem resumes normal operation, the relevant information, data and results of the temporary handling must be fully updated, reconciled and synchronized into the tax compliance and risk management subsystem in accordance with law.

Article 8. Application of tax compliance and risk management

1. Based on the results of the assessment and classification of the tax law compliance level under Article 10, the results of the assessment and classification of taxpayers’ risk level under Article 13 of this Circular and operational information available at the time of the decision, the tax authority shall apply management measures in the following areas:

a) Tax compliance management;

b) Risk management in tax registration;

c) Risk management in the examination of tax returns and other revenues at the tax authority’s premises;

d) Risk management in the management of tax refunds and other revenues;

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e) Risk management in the management of tax debts and other revenues and the enforcement of administrative tax management decisions;

g) Risk management in the management of tax exemptions and reductions;

h) Risk management in the management of invoices and vouchers;

i) Risk management for taxpayers subject to targeted monitoring and control;

k) Application of risk management in other tax administration operations.

2. The Tax Department shall provide detailed guidance on the assessment and classification of taxpayers’ tax law compliance level and risk level to meet tax administration requirements in each period.

3. The results of the assessment and classification of taxpayers’ compliance level and risk level shall be updated in the tax compliance and risk management subsystem. Tax authorities at all levels are responsible for synthesizing, updating and managing taxpayer compliance information and files, and the risk register, to serve tax administration work across the tax sector.

4. Where there is information giving rise to suspicion or where indicators of tax law violations are detected through inspections, examinations, audits, denunciation complaints or information from state agencies or investigative authorities, the head of the tax authority shall decide to change the form and level of examination or other tax administration measures within his or her authority and shall bear responsibility for such decision.

Article 9. Targeted monitoring and control of taxpayers showing indicators of tax law violations

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a) The taxpayer conducts transactions through banks that show suspicious signs in accordance with the law on anti-money laundering (AML) related to tax evasion or tax fraud.

b) The taxpayer or the taxpayer’s legal representative is subject to criminal prosecution for acts of tax or invoice and voucher violations.

c) The taxpayer shows high tax risk indicators related to priority audit themes or, through information collected in the course of the tax authority’s management work, requires tax administration monitoring and management.

d) The taxpayer is classified at the non-compliance level as prescribed in Article 10 of this Circular; the taxpayer fails to provide an explanation or supplement information, or provides an explanation or supplementation that is incomplete in accordance with the requirements and deadline stated in the tax authority’s written notification.

2. Tax authorities at all levels are responsible for monitoring, tracking and applying appropriate tax administration operational measures for each case under clause 1 of this Article.

3. The Tax Department shall provide specific guidance on the collection and analysis of information, identification of monitoring priorities, monitoring measures and monitoring periods in conformity with applicable law for each period.

Chapter II

TAX COMPLIANCE MANAGEMENT

Article 10. Classification of the tax law compliance level of taxpayers

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a) Level 1: Good compliance.

b) Level 2: Average compliance.

c) Level 3: Low compliance.

d) Level 4: Non-compliance.

2. The tax law compliance level of taxpayers shall be classified on the basis of the criteria prescribed in Appendix I to this Circular.

3. The results of the assessment and classification of taxpayers’ tax law compliance level shall be monitored and handled by the tax authority as follows:

a) For taxpayers classified at the non-compliance level, the tax authority shall apply management measures in accordance with Article 9 and compliance improvement measures in accordance with Article 11 of this Circular;

b) For taxpayers classified at the good compliance, average compliance and low compliance levels, the tax authority shall apply compliance improvement measures in accordance with Article 11 of this Circular.

Article 11. Measures to improve taxpayers’ tax law compliance

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1. For the case of good compliance:

a) To be placed on the list for consideration and selection for commendation and recognition in accordance with regulations applicable to taxpayers with good tax law compliance.

b) To be granted preferential treatment in tax administration where all conditions prescribed in Article 48 of Decree No. 252/2026/ND-CP are fully met.

2. For cases requiring compliance improvement:

a) Coordinate with relevant state agencies, related organizations and tax agents to implement compliance improvement measures and support and guidance measures to assist taxpayers in carrying out tax procedures; organize taxpayer outreach programs, dialogue conferences and workshops to help taxpayers properly and fully fulfill their tax obligations;

b) Research and propose amendments to policies, simplify administrative procedures, implement support measures, promote the application of information technology and create favorable conditions for taxpayers in tax declaration and payment, saving time and reducing compliance costs for taxpayers;

c) Carry out risk classification and apply tax administration measures corresponding to taxpayers’ risk levels as prescribed in Articles 13, 14, 15, 16, 17, 18, 19 and 20 of this Circular.

Article 12. Monitoring and evaluation of the implementation of the compliance improvement plan

1. Matters subject to monitoring and evaluation:

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b) The results and effectiveness of the implementation of the compliance improvement plan;

b.1) The effectiveness and efficiency of the application of handling measures implemented by tax authorities at all levels on the basis of analysis and risk identification for each taxpayer subgroup;

b.2) Comparison and evaluation of the actual results achieved against the expected results in the implementation of risk mitigation measures through compliance measurement.

c) The application of transparent processes in developing and implementing the compliance improvement plan;

d) The improvement of the overall compliance level of taxpayer groups and each type of different tax obligation;

dd) The organizational apparatus and human resources of tax authorities at all levels in the implementation of the plan to ensure the effectiveness and efficiency of tax administration in accordance with the stated objectives.

2. Monitoring and evaluation measures:

a) Synthesis, monitoring and analysis of information and reporting data from tax authorities at all levels, and the Divisions and Sub-departments under the Tax Department in the course of the implementation of the compliance improvement plan;

b) Collection and synthesis of implementation results; analysis of the impact of measures implemented and proposals for adjustments and supplementation of measures to enhance the effectiveness of the plan’s implementation; review and update of the risk register, and removal of risks that are no longer relevant.

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3. Responsibilities of units:

The Director of the Tax Department shall assign the units tasked with tax compliance and risk management to monitor and evaluate the implementation of the compliance improvement plan and report to the superior authority in accordance with clause 2 of this Article. Monitoring and evaluation shall be conducted on a regular basis, with mid-term reports (June of each year) and year-end reports (December of each year), and ad hoc reports as required on the progress of the implementation of the compliance improvement plan.

Chapter III

TAX RISK MANAGEMENT

Article 13. Classification of the risk level of taxpayers

1. The risk level applicable to taxpayers in each tax administration operation shall be classified according to one of the following levels:

a) High risk.

b) Medium risk.

c) Low risk.

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3. Handling of the results of risk level classification:

The results of the classification of taxpayers’ risk level shall be applied to tax administration measures in each tax administration operation as prescribed in Articles 14, 15, 16, 17, 18, 19 and 20 of this Circular.

Article 14. Application of risk management in tax registration management

Based on the list of taxpayers classified by risk level in tax registration management under Article 13 of this Circular, the tax authority shall apply appropriate tax administration measures in resolving, handling or coordinating with the business registration authority to resolve and handle matters in accordance with the law on business registration and tax registration.

1. Change of tax registration information resulting in a change of the directly managing tax authority:

a) High risk: The tax authority of the transferring locality shall conduct an examination at the taxpayer’s premises in accordance with law;

b) Medium risk: The tax authority of the receiving locality shall place the taxpayer under monitoring and request the taxpayer to provide explanation and supplement information and documents as required by the tax authority;

c) Low risk: No examination or monitoring shall be conducted at this stage; the assessment and classification of the taxpayer’s tax law compliance level and risk level shall be carried out for the next assessment period.

2. Where a taxpayer notifies the suspension of operations or business:

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b) Medium risk and low risk: Apply tax administration measures in accordance with law; carry out the assessment and classification of the taxpayer’s tax law compliance level and risk level for the next assessment period.

3. Where the tax identification number is terminated:

a) High risk: Conduct a tax examination at the taxpayer’s premises in accordance with law.

b) Medium risk and low risk: Apply measures to urge the taxpayer to fulfill all tax obligations before dissolution, bankruptcy or cessation of operations in accordance with law.

4. Restoration of the tax identification number:

a) High risk: Conduct a review and examination in accordance with law before restoring the taxpayer’s tax identification number.

b) Medium risk and low risk: Restore the taxpayer’s tax identification number in accordance with law.

5. For other cases: Regularly review cases showing high-risk indicators to identify the list requiring review and verification of the operational status at the taxpayer’s registered address.

Article 15. Application of risk management in the examination of tax returns and other revenues at the tax authority’s premises

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1. High risk: Analyze the tax returns, prepare a list and submit to the head of the tax authority an examination plan at the tax authority’s premises, and conduct examinations of tax returns and other revenues at the tax authority’s premises in accordance with law.

2. Medium risk and low risk: No examination of tax returns or other revenues at the tax authority’s premises shall be conducted at this stage; the assessment and classification of the taxpayer’s tax law compliance level and risk level in respect of tax returns and other revenues shall be carried out for the next assessment period.

Article 16. Application of risk management in tax refunds and other revenues

The tax authority shall classify taxpayers with tax refund applications in accordance with the Law on Tax Administration No. 108/2025/QH15, its guidance documents and other relevant laws. For the risk classification of taxpayers with tax refund applications, based on the classification results under Article 13 of this Circular and operational information available at the time of issuance of the tax refund decision, the tax authority shall apply appropriate measures in resolving and handling tax refund applications as follows:

1. For taxpayers with VAT refund applications.

a) High risk:

a.1) Apply pre-refund examination (except for the case prescribed in point a.2 of this clause).

a.2) Where a taxpayer’s refund application is classified as high risk by the same one or more risk indicators in the non-scoring criteria group compared to the immediately preceding tax refund application, the taxpayer’s tax refund application shall be subject to post-refund examination where the result of the examination of the immediately preceding tax refund application did not detect any incorrect declaration resulting in a shortfall in tax payable or an increase in the refundable tax amount, and the application does not fall within the high-risk category under any other scoring criteria group.

b) Medium risk and low risk:

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On the basis of applicable tax laws, the taxpayer’s tax refund application and information managed by the tax authority in the database, the tax compliance and risk management subsystem shall determine and produce the risk-free tax refund amount in accordance with law.

b.2) For the tax refund amount showing risk indicators, the tax authority shall suspend the tax refund to collect information and carry out a review and examination in accordance with law.

Within two years from the date of issuance of the tax refund decision, the tax authority shall collect information and carry out a review and examination of the suspended refund tax amount of the taxpayer and handle the suspended refund tax amount following the review and examination in accordance with law.

Based on the scope and coverage of the request of the tax authority resolving the tax refund, the tax authority managing the taxpayer that issued the invoices shall be responsible for coordinating the exchange of information or conducting an examination at the tax authority’s premises or an examination at the taxpayer’s premises in accordance with law, ensuring timely, complete and lawful information exchange.

b.3) The Tax Department shall provide specific guidance on: the risk-free tax amount, the at-risk tax amount; the review and examination of the suspended refund tax amount; and the handling of the suspended refund tax amount following the review and examination.

2. For taxpayers with other tax refund applications and other revenues (hereinafter referred to as other tax refund applications).

a) High risk: Apply pre-refund examination.

b) Medium risk and low risk: Apply post-refund examination.

3. Reclassification of tax refund applications:

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4. Post-refund examination:

a) Within five years from the date of issuance of the tax refund decision, the tax authority shall conduct post-refund examinations on the basis of the risk level classification results from high to low, in specific:

- For taxpayers with high-risk tax refund applications that do not fall within the pre-refund examination category as prescribed in point a.2 of point a, clause 1 of this Article: Within one year from the date of issuance of the tax refund decision, the tax authority shall conduct a post-refund examination;

- For taxpayers with medium-risk tax refund applications: Within three years from the date of issuance of the tax refund decision, the tax authority shall conduct a post-refund examination;

- For taxpayers with low-risk tax refund applications: Within five years from the date of issuance of the tax refund decision, the tax authority shall conduct a post-refund examination.

Based on the actual situation and tax administration requirements, the tax authority may conduct a post-refund examination before the above-mentioned deadlines.

b) The Tax Department shall provide specific guidance on post-refund examinations, combined with examinations of tax law compliance in accordance with law.

Article 17. Application of risk management in examinations at taxpayers’ premises

1. Principles for selecting cases for examination at taxpayers’ premises:

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b) Randomly selected cases shall account for no more than 10% of the total number of cases for examination under the annual plan.

2. Selection of taxpayers for the development of the examination plan at taxpayers’ premises.

Based on the list of taxpayers classified by risk level under Article 13 of this Circular, the tax authority shall select cases for examination at taxpayers’ premises as follows:

a) Select taxpayers to be included in the annual examination plan at taxpayers’ premises according to the risk level classification results from high to low.

b) The selection of taxpayers showing risk indicators for the development of the examination plan at taxpayers’ premises shall not overlap in scope, coverage and timing with other tax examination activities and other inspection and examination activities in accordance with the Law on Tax Administration No. 108/2025/QH15, its guidance documents and other relevant laws.

c) Where, in the course of tax administration, the tax authority has reliable information that reduces a taxpayer’s risk level to low or has grounds to consider that the taxpayer’s risk level is low and the taxpayer has not been included in the annual examination plan, the tax authority shall decide not to select that taxpayer for the examination plan and shall select another taxpayer in accordance with law for inclusion in the annual examination plan. Where, in the course of tax administration, information is collected and verified establishing that a taxpayer shows high-risk indicators, the tax authority shall add the taxpayer to the annual examination plan. The tax authority shall bear responsibility for its own decisions to change the plan.

d) The development and the authority to approve the annual examination plan at taxpayers’ premises; the list of additions to and adjustments of the examination plan at taxpayers’ premises under this Article shall be carried out in accordance with the Law on Tax Administration No. 108/2025/QH15, its guidance documents and other relevant laws.

3. The tax authority shall use the results of risk analysis through information technology applications or risk analysis from operational analysis and information gathered in the course of tax administration to determine cases for examination, the scope, coverage and timing of tax examinations.

Article 18. Application of risk management in the management of tax debts and other revenues and the enforcement of administrative tax management decisions

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1. For taxpayers with a high risk level: Increase the frequency of monthly monitoring, strengthen debt collection follow-up measures and direct engagement to ensure timely collection of outstanding debts into the state budget, including the application of exit suspension measures; select and apply one or more measures for the enforcement of administrative tax management decisions to ensure timely and full collection of outstanding tax debts into the state budget; and make public disclosures of tax debt information.

2. For taxpayers with a medium risk level: Monitor on a monthly basis, apply follow-up reminders, provide advice and support to taxpayers in fulfilling their tax payment obligations, apply exit suspension in accordance with the prescribed thresholds, make public disclosures of tax debt information in accordance with point a, clause 3, Article 7 of the Law on Tax Administration No. 108/2025/QH15, and apply measures for the enforcement of administrative tax management decisions in the sequence prescribed by the Law on Tax Administration No. 108/2025/QH15 and its guidance documents.

3. For taxpayers with a low risk level: Apply follow-up reminders, provide advice and support to taxpayers in fulfilling their tax payment obligations; exit suspension measures may be withheld and measures for the enforcement of administrative tax management decisions may be withheld in accordance with the Law on Tax Administration No. 108/2025/QH15 and its guidance documents.

Article 19. Application of risk management in the management of tax exemptions and reductions

The tax authority shall manage tax exemption and reduction applications in accordance with the Law on Tax Administration No. 108/2025/QH15 and its guidance documents; and shall simultaneously apply risk management in the course of processing tax exemption and reduction applications. Based on the results of the risk level classification under Article 13 of this Circular, the tax authority shall apply measures corresponding to the risk level as follows:

1. High risk: Conduct an examination at the taxpayer’s premises in accordance with law.

2. Medium risk and low risk: Receive and resolve tax exemption and reduction applications strictly in accordance with the prescribed processes and procedures; and simultaneously carry out monitoring and examination following the resolution of the tax exemption and reduction application in accordance with the plan or where risk indicators arise.

Article 20. Application of risk management in the management of invoices and vouchers and other tax administration operations

1. Application of risk management in invoice and voucher use management.

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a) High risk: The tax authority shall apply appropriate management measures including: refusal to accept registration for use of e-invoices, suspension of e-invoice use or other invoice management measures in accordance with law.

b) Medium risk and low risk: Conduct sampling for review, examination and handling in accordance with law; strengthen the monitoring and analysis of invoice and voucher data to promptly detect and prevent emerging risks; and provide support and guidance to taxpayers to comply properly with the law on invoices and vouchers.

The Tax Department shall provide guidance on appropriate sampling methods in accordance with the tax administration requirements of each locality and for each period.

2. Application of risk management in other operations.

Based on the risk level in other operational activities and operational information, the tax authority shall decide to apply appropriate operational measures in accordance with its functions and duties.

Article 21. Inspection and evaluation of the application of risk management in tax administration

1. Matters subject to inspection and evaluation.

The inspection and evaluation of the application of risk management in tax administration shall focus on the following matters:

a) The quality of the organization and implementation of risk management measures and operations;

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c) The organization and the results of the implementation of examination decisions or other operational measures carried out on the basis of the application of risk management;

d) The effectiveness of the system of criteria and indicators for the assessment and classification of taxpayers’ tax law compliance level and risk level.

2. Inspection and evaluation measures.

Inspection and evaluation shall be carried out through the following measures:

a) Synthesis, analysis of information and reporting data from tax authorities at all levels and units under the Tax Department on the status of the implementation and application of risk management;

b) Collection, analysis and synthesis of information and data on the results of the application of risk management in tax administration operations;

c) Organization of working delegations to inspect the implementation and application of risk management at tax authorities at all levels in accordance with law.

3. Responsibilities of units.

The Director of the Tax Department shall assign relevant units and units tasked with tax compliance and risk management to inspect and evaluate the application of risk management in tax administration and report to the superior authority in accordance with clause 2 of this Article. Evaluation shall be conducted on a regular basis, with periodic reports (every six months and annually) and as required by arising operational needs.

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ENFORCEMENT PROVISIONS

Article 22. Implementation responsibilities

1. The Director of the Tax Department, based on the provisions of this Circular, is responsible for issuing:

a) Sets of criteria and indicators as prescribed in Articles 10 and 13 of this Circular to meet tax administration requirements in each period; conducting a review on an annual basis or as required by tax administration needs to revise and supplement the criteria and indicators to ensure they remain up-to-date and suited to practical conditions;

b) Specific guidelines on the responsibilities of tax authorities at all levels, tax officers and measures for the collection and processing of tax compliance and risk management information; scores, weights and technical measures for tax compliance and risk management;

c) Processes, regulations, rules and guidelines for the implementation and application of tax compliance and risk management.

2. The unit tasked with tax compliance and risk management is the lead coordinating unit responsible for:

a) Managing and coordinating the operation of the tax compliance and risk management subsystem and information and data systems serving tax compliance and risk management as assigned;

b) Organizing the implementation and providing operational guidance, and inspecting the collection and processing of tax compliance and risk management information; operational measures and techniques and the application of tax compliance and risk management in tax administration operations;

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3. State agencies in coordinating state management on taxes; taxpayers; organizations and individuals related to tax administration activities; provincial/municipal Tax Departments, local tax departments, Divisions, units, large enterprise tax sub-departments and e-commerce tax sub-departments under the Tax Department, and tax officers are responsible for fully and properly implementing the provisions on the implementation and application of tax compliance and risk management under this Circular and other relevant regulatory documents.

Article 23. Entry into force

1. This Circular comes into force as of July 1, 2026.

2. This Circular replaces Circular No. 31/2021/TT-BTC of May 17, 2021 of the Minister of Finance on the application of risk management in tax administration.

3. Where new legal normative documents are issued amending or replacing the documents referenced in this Circular, the amending or replacing documents shall govern.

PP. MINISTER
DEPUTY MINISTER




Cao Anh Tuan