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TAX ADMINISTRATION LAW 108/2025/QH15

On December 10, 2025, the 15th National Assembly passed the Tax Administration Law 2025 (Law No. 108/2025/QH15). The Law marks a significant change in tax administration, shifting toward data- and risk-based management, with a broad scope of impact ranging from large enterprises to small and medium-sized businesses, as well as households and individual business owners.

Below is a summary of several new provisions in the Tax Administration Law 2025 enacted by the National Assembly:

1. Tax Inspection

Before the new Law was enacted, there were two forms of inspection conducted by tax authorities in Vietnam: tax audits with an in-depth scope and tax inspections with a more limited scope.

Under the Tax Administration Law 2025, provisions related to tax audits have been abolished and replaced with mechanisms for online, remote inspections based on electronic data. From now on, all audit activities will be uniformly regulated under the Law on Inspection.

At the same time, the new Law significantly revises the regulations on tax inspections, specifically

  • The duration of tax inspections at the taxpayer’s premises is increased to a maximum of 20 calendar days, and in necessary cases may be extended for an additional 20 calendar days. This replaces the previous mechanism under the 2019 Tax Administration Law (10 working days with a possible extension of 10 working days).
  • For inspections of related-party transactions (transfer pricing), the Law for the first time sets a separate time limit: a maximum of 40 calendar days, extendable by another 40 days, and allowing up to 2 years in cases involving international information exchange. Previously, the 2019 Tax Administration Law did not distinguish transfer pricing inspections from ordinary tax inspections.
  • In addition, certain types of inspections at the premises (such as periodic inspections or corporate restructuring) may only be conducted once per year. The Law also authorizes higher-level tax authorities to re-inspect cases that have already been concluded, applying the same time limits as the initial inspection, and requiring such re-inspections to be carried out within 2 years from the date of issuance of the conclusion or penalty decision.

2. Notable Changes

The new Tax Administration Law introduces numerous adjustments to tax management and compliance procedures, including mechanisms to support taxpayers as well as stricter procedural requirements. The positively assessed points and matters requiring attention are as follows:

  • Taxpayers may be exempted from fines and late payment interest if delays in fulfilling tax obligations arise from technical failures of the tax authority’s system.
  • The Law establishes an automated mechanism for handling tax refunds, exemptions, and reductions, based on electronic data, risk management models, automated processing procedures, and information security safeguards within the tax administration system.
  • The deadline for supplementary tax declarations is reduced from 10 years to 5 years from the filing due date. Supplementary declarations are only accepted if submitted before a tax inspection decision is issued for the relevant period, or if the supplementary content does not fall within the scope or period of inspection.
  • Fulfillment of tax obligations prior to exit: applicable to beneficial owners and legal representatives of enterprises in cases where the enterprise is subject to enforcement of tax decisions or has ceased operations at its registered address.
  • Household businesses and individual business owners with revenue not subject to tax or exempt from tax are only required to notify the tax authority of their actual revenue. In cases where revenue is taxable, they must declare and calculate each type of tax according to the applicable tax period.
  • Target enterprises in Vietnam must declare and pay taxes on behalf of indirect capital transfers between foreign organizations.
  • The scope of taxpayers is expanded to include foreign organizations and individuals earning income in Vietnam and conducting business on e-commerce/digital platforms, in alignment with the new VAT Law (effective July 1, 2025) and the new Corporate Income Tax Law (effective October 1, 2025).
  • For business activities conducted on e-commerce/digital platforms:

– platform operators are responsible for withholding, declaring, and paying taxes on behalf of taxpayers.

– In cases where these functions are not available, tax obligations fall on household businesses and individual business owners.

3. Transitional Provisions and Effective Date

Tax amounts exempted, reduced, or not collected under the laws applicable to each period, arising before July 1, 2026, shall continue to be handled in accordance with the 2019 Tax Administration Law.

Tax debts outstanding as of June 30, 2026, shall be handled in accordance with the 2025 Tax Administration Law.

The 2025 Tax Administration Law takes effect on July 1, 2026, except for Article 13 and the provisions on electronic invoices for households and individual business owners (Article 26), which take effect on January 1, 2026.