Explanation of Key Points in Tax and Accounting Reforms in Vietnam in 2025
2025/06/29
- Bui Thi Hang
1．Value-Added Tax Law
On November 26, 2024, the National Assembly passed the Value-Added Tax Law (VAT) No. 48/2024/QH15. This law replaces the 2008 Value-Added Tax Law and will come into effect on July 1, 2025.
The main amendments are as follows.
(1) Expansion of the scope of taxpayers
The following entities have newly been added as taxpayers.
| Applicable parties | Specific details |
| Overseas businesses | Businesses without a permanent establishment in Vietnam that conduct business through e-commerce or digital platforms |
| Platform administrators, e-commerce administrators | Platform administrators and e-commerce administrators who withhold and remit taxes on behalf of the above overseas businesses or individuals operating on the platforms |
(2) Review of Applicable Scope for 0% Tax Rate
The 0% tax rate for overseas goods and services will be maintained, but for supplies to organizations within bonded areas, a new condition requiring direct relevance to export activities has been added.
(3) Review of Eligible Scope for 5% Tax Rate
Certain industries, such as film-related services, will be excluded from the 5% tax rate, while some fertilizer products, fishing vessels, and agricultural machinery have been reclassified from tax-exempt to 5% taxable items.
(4) New Requirements Relating to Payment Methods for Deductions
To receive VAT deductions, non-cash payments are generally required. Although cash payments might continue to be permitted in the future, it is expected that their upper limit will be lowered from the current 20 million VND.
The specific limit will be stipulated in decrees and circulars to be announced in the future.
(5) Revision of the VAT refund system
Refund applications for capital investments in new projects have been permitted up to now. On the other hand, refunds for investments related to the expansion of existing projects have been denied. With this revision, it has been clearly indicated that expansion investments meeting the requirements set by law and regulations are also eligible for refunds.
The deadline for refund applications is within one year from the completion date of the investment project or its respective phase/item.
In addition, the VAT refund system related to changes in corporate ownership, business transformation, mergers, consolidations, divisions, or spin-offs will be officially abolished.
2．Clarification of invoice issuance rules
With Decree No. 70/2025/NĐ-CP promulgated on March 20, 2025, the existing regulations concerning invoices and vouchers have been revised, and will come into effect on June 1 of the same year. This decree clarifies the rules regarding the timing of invoice issuance, with the main points as follows.
| Type of Transaction | Timing of Invoice Issuance |
| Sale of goods | At the time ownership or the right to use is transferred to the buyer (regardless of whether payment has been received) |
| Export transaction | No later than the next business day after customs clearance is completed |
| Service Provision | At the time the service is completed (including service provision to foreign corporations and individuals), regardless of whether payment has been received. If payment is made before or during the provision of the service, the time of invoice issuance is considered to be the time of payment. However, this excludes the collection of security deposits or advance payments related to the service provision. (Accounting, audit, consulting related to finance and taxation, assessment reviews, technical design and investigations, supervisory consultants, and formulation of construction investment projects) |
| Partial Delivery | An individual invoice is required each time a delivery is made. |
| Casinos, electronic games, etc. | Issuance required by the day after the revenue recognition date. |
3．Criteria for temporary suspension of entry and exit clarified.
On February 28, 2025, the government promulgated Decree No. 49/2025/NĐ-CP, which sets out standards for temporarily suspending entry and exit, and enforced it on the same day.
This decree allows for the temporary restriction of entry and exit for taxpayers and their representatives who have unpaid taxes, provided certain conditions are met.
(1) Sole proprietors and representatives of family-run businesses.
| Condition items | Details |
| Unpaid tax amount | 50 million VND or more (approximately 300,000 yen) |
| Elapsed period | 120 days or more have passed since the payment due date |
(2) Corporate legal representative
| Condition items | Details |
| Unpaid Tax Amount | 500 million VND or more (approximately 3 million yen) |
| Elapsed Period | 120 days or more after the tax payment deadline |
| Other Conditions | In cases subject to compulsory enforcement under Article 124 of the Tax Administration Law No. 38/2019/QH14 |
*”Tax Administration Law No. 38/2019/QH14 Article 124″ refers to a situation in which compulsory execution (such as property seizure) for tax debt collection has commenced.
(3) Sole proprietors, family business representatives, and corporate representatives not operating at their registered address
| Criteria Item | Details |
| Self-employed individuals, heads of family businesses, or corporate representatives not operating at their registered location | In cases of unpaid taxes (regardless of amount or period) |
(4) Additional screening for special departing individuals
| Criteria Item | Details |
| Departing individuals intending to immigrate abroad (Vietnamese nationals), Vietnamese nationals already residing abroad, foreigners prior to leaving Vietnam | In cases where taxes have not been paid (regardless of the amount or period) |
*”Unpaid taxes” includes not only the principal amount of taxes but also any late fees and penalties.
Notifications to individuals concerned will be made through the etaxmobile app, the electronic transaction website (https://thuedientu.gdt.gov.vn), registered email addresses, and so on. If direct transmission from the authorities is not possible, the notification will be posted on the official website of the tax authority. It is recommended that taxpayers regularly check their own tax obligations and, in particular, ensure there are no outstanding taxes before leaving the country.
4. Expected Upcoming Announcements on Tax and Accounting Revisions
From 2025 onwards, several revisions and new decrees related to tax and accounting systems are scheduled to be announced in Vietnam. Companies are expected to stay informed about these upcoming developments. The following are the main systems expected to be announced or enacted in the near future.
・Amendment to the Corporate Tax Law (Scheduled to take effect: January 1, 2026)
This amendment bill is expected to be reviewed and enacted at the National Assembly (9th session) scheduled for May 2025. The details of the revisions have not yet been announced, but in light of recent global tax trends, it is possible that the contents will include a review of preferential systems and consideration for international consistency.
・Amendment of the Individual Income Tax Act(Scheduled enforcement: January 1, 2027)
It is scheduled to be submitted to the Diet in October 2025, is expected to be enacted in May of the same year, and to take effect from January 2027. A review of income categories, deduction systems, and tax rate structures is likely to be discussed, and significant impacts on the current system are expected.
・Government ordinance on prevention of global tax base erosion (BEPS)
To comply with the OECD’s “Global Minimum Tax,” the introduction of a supplementary corporate income tax system is scheduled based on National Assembly Resolution No. 107/2023/QH15 dated November 29, 2023. Although this government ordinance was initially scheduled to be promulgated in 2024, it has been postponed to 2025 after adjustments. As a result, a minimum effective tax rate of 15% is expected to be applied to multinational corporations.
・Government ordinance on the Implementation of the Value Added Tax Law No. 48/2024/QH15(Scheduled promulgation: before July 2025)
Supplementary government ordinances are expected to be promulgated as practical guidelines for the new Value-Added Tax law scheduled to take effect in July 2025. It is expected that essential details such as the scope of applicable tax rates, refund requirements, and interpretations of non-taxable transactions will be clarified to facilitate business operations, and advance review and preparation are recommended.
・Resolution on continuing the reduced VAT rate
Currently, until June 30, 2025, the VAT rate for certain goods and services has been reduced from 10% to 8%. A proposal to extend this until the end of 2026 was submitted to the Diet by the government on April 23, 2025. If this resolution is passed, it is expected that the tax rate reduction will be implemented for two consecutive years, and the impact on sales management and invoice issuance operations will continue.
・Full revision of the corporate accounting system notice(date of promulgation undecided)
The Ministry of Finance has published a draft of a new notice as a replacement for Notice No. 200/2014/TT-BTC dated December 22, 2014, related to the corporate accounting system. This is intended as a phased transition to IFRS, and although it was initially scheduled to come into effect in January 2025, its promulgation may be delayed until the end of 2025 or the beginning of 2026. In the initial stage, large enterprises will be subject to it, but in the future, it is expected to affect medium-sized companies as well.
References:：
Value Added Tax Law No. 48/2024/QH15
Decree No. 70/2025/NĐ-CP
Decree No. 49/2025/NĐ-CP
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