Summary:

On December 10, 2025, the National Assembly of the Socialist Republic of Vietnam promulgated the Law on Tax Administration No. 108/2025/QH15, which will generally take effect on July 1, 2026, with certain provisions effective earlier. The law introduces changes to the tax administration framework, including categorization of taxpayers and a shorter time limit for supplementary tax declarations, among other administrative provisions relevant to tax compliance.

Key points:

Taxpayer Categorization

The law expands and clarifies the definition of “taxpayers.” Under Article 2, taxpayers include organizations, business households, individuals, and foreign entities or individuals that conduct business activities in Vietnam or earn income arising in Vietnam under tax law provisions.

Supplementary Tax Declaration Time Limit

The law shortens the period for taxpayers to submit supplementary tax declarations or declarations of other revenue. Previously governed by earlier rules, the time limit is reduced to five years from the deadline for submitting tax returns or other revenue declarations. This applies to instances where taxpayers discover omissions or errors and seek to correct prior submissions before tax examination or inspection decisions are announced.

Transfer of Investment Projects and Capital Transfer Obligations

The law specifies tax payment obligations where investment projects or capital transfers occur. Organizations or individuals established under Vietnamese law that transfer investment projects or capital are responsible for fulfilling their tax payment obligations arising from project or capital transfer activities as prescribed by tax law. If a transfer involves foreign entities, the law sets out responsibilities for determination, declaration, withholding, and payment of taxes by the transferees on behalf of the transferors in accordance with tax law provisions.

Electronic Tax Administration and Implementation Timeline

Under Article 52, the law stipulates that tax authorities are responsible for building and enhancing digital systems to support e-transactional processes in tax management. The full application of electronic transaction methods in tax administration is to be completed by the timeline prescribed by the Minister of Finance (ensuring legal effect of such electronic administrative decisions).

Source:

National Assembly of the Socialist Republic of Vietnam, Law on Tax Administration No. 108/2025/QH15 (December 10, 2025; effective July 1, 2026). Official Gazette information available on the Government’s e-publication portal.

Link to official text (Vietnamese): https://congbao.chinhphu.vn/van-ban/luat-so-108-2025-qh15-468670/61635.htm

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Disclaimer:

This content is for general informational purposes only and does not constitute professional advice.

Information provided herein is based on publicly available sources as of the publication date and may be subject to change.

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