Many foreign employees fail to secure a Thailand work permit not because they lack qualifications but because they do not grasp the real world process. Navigating complex documents and shifting regulations can be overwhelming especially since success depends heavily on the employer. This guide provides a strategic roadmap to ensure approval by framing the process through accuracy and legal compliance. Because this is a legal topic involving work authorization, following these steps precisely is essential for a successful career in the Land of Smiles.

Thailand Work Permit Requirements Overview for Foreign Employees

What Is a Thailand Work Permit and Who Needs It for New Expats

A Thailand work permit is a legal document that authorizes a non Thai national to work and earn income within the country. It is mandatory for anyone engaging in work, whether physical or professional, regardless of the duration or type of activity.

Difference Between Foreign Employee, Freelancer, and Business Owner for Digital Nomads

Foreign employees typically require a company sponsor to obtain a work permit. Freelancers and digital nomads often operate in a legal gray area unless they use structured visa options such as the LTR visa or SMART visa. Business owners, on the other hand, must establish a registered company that meets minimum capital and staffing requirements to sponsor their own work permit.

Relationship Between Job Offer and Eligibility for Job Seekers

Eligibility for a Thailand work permit begins with a valid job offer. Individuals cannot apply independently without employer sponsorship. Additionally, the position must not fall under occupations restricted to Thai nationals under local labor laws.

Relevant Visa Types Such as Non Immigrant B Visa and Business Visa for Beginners

The most common route is the Non Immigrant B visa. This visa acts as the initial entry requirement, allowing foreign nationals to enter Thailand and proceed with the work permit application process once inside the country.

Minimum Salary Requirements Based on Nationality and Position for Professionals

The Thai government enforces minimum salary thresholds that vary depending on the applicant’s nationality and job role. This policy ensures that foreign workers contribute a defined level of income tax to the local economy.

Why Thailand Work Permit Requirements Are More Complex Than You Think

Why Approval Depends on the Company Rather Than the Individual for Expats

Work permit approval in Thailand is primarily employer driven. Even if you are a highly skilled professional, your application can be rejected if the sponsoring company fails to meet key requirements such as tax compliance or social security contributions.

The Company’s Role in Meeting Legal and Tax Requirements for HR and Business Owners

The sponsoring company must demonstrate that it is a legitimate and financially stable business. This typically involves submitting audited financial statements, VAT registration documents, and proof of ongoing operations. These requirements allow the labor department to verify that the company can support and legally employ foreign talent.

Real Case Scenarios Where Applications Are Rejected Despite Complete Documents

Work permit applications are often rejected even when all documents appear complete. Common reasons include the company not meeting the minimum paid up capital requirement or failing to maintain the legally required ratio of Thai to foreign employees during the application period.

Difference Between Visa Approval and Work Permit Approval for Beginners

Visa approval allows you to enter and stay in Thailand, while work permit approval grants you the legal right to perform a specific job. Both are required to work legally, but they are processed by different government authorities and must be handled separately.

To work in Thailand, you must first obtain a work visa, commonly referred to as a Thai work visa, which is typically the Non Immigrant Visa Category B (sometimes called immigrant visa category B). The visa category B is the standard non immigrant visa category for business and employment purposes. Securing a Non Immigrant Visa Category B is a key requirement for those seeking to work or conduct business in Thailand, and it must be obtained before you can apply for a work permit.

Types of Visas Linked to Thailand Work Permit Requirements

Complete Document Checklist for Thailand Work Permit Application

Documents Required from the Foreign Employee for Beginners

Applicants must provide a valid passport with at least six months of remaining validity, along with their educational certificates. Depending on the role, additional documents such as professional licenses or specialized training certifications may also be required.

Documents Required from the Employer Such as Company Registration for HR

The employer is responsible for submitting extensive documentation, including the company registration certificate, shareholder list, and the previous year’s audited financial statements. These documents are essential to prove the company’s legal and financial standing.

Additional Documents Depending on Industry for Specialized Workers

Certain industries, such as education and healthcare, require extra approvals. This may include endorsement letters or certifications from relevant regulatory bodies or government ministries to authorize the applicant’s role.

How to Ensure Documents Are Not Rejected Including Formatting and Legalization

All foreign issued documents must be translated into Thai and, in many cases, notarized or legalized by the appropriate embassy. Even minor translation errors or formatting inconsistencies can lead to delays or rejection, making accuracy critical.

Step by Step Thailand Work Permit Application Process

Step 1 Secure a Job Offer and Company Sponsorship for Job Seekers

The process begins by securing a formal job offer from a Thai registered company that is willing to act as your sponsor. Without employer sponsorship, you cannot proceed with a work permit application.

Step 2 Apply for a Non Immigrant B Visa Outside Thailand for New Expats

Once you receive the necessary sponsorship documents from your employer, you must apply for a Non Immigrant B visa at a Thai embassy or consulate outside Thailand. This visa is required before entering the country for work purposes. In addition to the standard Non Immigrant B visa, there is a business approved visa (Non Immigrant B A), which is typically granted to foreign investors in Thailand, allowing them to work in their own businesses, though it is rarely issued and depends on the discretion of the embassy or consulate. For those working on projects approved by the Board of Investment of Thailand (BOI), the investment and business visa (IB visa) is designated to facilitate employment and investment opportunities in BOI promoted projects. There is also a media visa available for foreigners working in media industries such as television, film, and online media, often requiring approval from relevant Thai authorities. Additionally, the non immigrant O visa is intended for accompanying family members, retirees, volunteers, or individuals married to Thai citizens, depending on eligibility and purpose.

Step 3 Enter Thailand and Submit Your Work Permit Application for Beginners

After entering Thailand with your Non Immigrant B visa, you will have a limited timeframe to visit the Ministry of Labor and submit your physical work permit application. Timely submission is crucial to avoid delays or compliance issues.

Minimum Salary and Company Requirements Explained Clearly

Minimum salary berdasarkan nationality dan role untuk expat

The minimum salary for Westerners is typically 50,000 THB per month. For citizens of other regions like East Asia the requirement may be 35,000 THB while some neighboring countries have lower thresholds.

Rasio employee lokal vs foreign employee untuk business owner

For every one foreign employee the company must generally employ four full time Thai staff. There are exceptions for companies promoted by the Board of Investment BOI.

Capital requirement perusahaan untuk investor

The sponsoring company must have a minimum paid up capital of 2 million THB per foreign work permit issued.

Bagaimana perusahaan optimize agar lolos requirement

Companies often use the BOI promotion to reduce the 4 to 1 staff ratio requirement or to lower the capital requirement hurdles.

Common Reasons Work Permit Applications Get Rejected

Invalid or incomplete documents for beginners

Missing signatures or using expired company documents will result in an immediate return of the application.

The company does not meet the legal requirements to be an employer

If the company has any outstanding tax issues or has failed to file its latest financial statements the government will pause all work permit approvals for that entity.

The job role does not match the qualifications required for the position

If you are hired as a software engineer but your degree is in an unrelated field like fine arts the labor department may question your eligibility for the role.

How to audit an app before submission

Review every page for the company seal and the authorized director signature. Ensure that the medical certificate is from a recognized Thai hospital and is not older than 30 days.

Practical Tips to Get Your Thailand Work Permit Approved Faster

How to Choose a Visa Friendly Employer for Job Seekers

Look for companies that already employ several foreign workers. These companies typically have experienced HR teams who understand the bureaucratic process, significantly increasing your chances of approval.

How to Speed Up the Process Through HR Coordination for Expats

Prepare all required documents in advance, including educational transcripts and medical certificates. Having clear digital copies ready can save days of back and forth communication with your employer and authorities.

Small Mistakes That Can Delay Approval

Simple errors can cause major delays. For example, using the wrong ink color for signatures or failing to sign every page of your passport copies may result in processing delays of up to a week or more.

Final Checklist Before Submission for All Applicants

Double check critical details such as the visibility of the company seal, the validity of your Non Immigrant B visa stamp, and the accuracy of your name in Thai translations. Small inconsistencies can lead to rejection or delays.

Obligations of Foreign Workers in Thailand

Once you have secured your Thai work permit and started working under a Non Immigrant B visa, it is essential to understand and fulfill your ongoing legal obligations to remain compliant. One of the most important requirements is the 90 day reporting to the Immigration Bureau. Every foreign worker must notify the Immigration Bureau of their current address in Thailand every 90 days, whether in person, by mail, or through an authorized agent. Missing this deadline can result in fines and complications with your work permit status.

If you plan to travel outside Thailand during your employment, you must obtain a re entry permit before leaving. Without a valid re entry permit, your Non Immigrant B visa and work permit may be automatically canceled upon departure, requiring you to restart the application process from scratch. Always ensure your re entry permit is secured and valid for the duration of your travel.

Additionally, Thai law requires foreign workers to carry their work permit at all times while in the country. Government officials may request to see your work permit during inspections or routine checks, and failure to present it can lead to fines or other penalties. Staying vigilant about these obligations helps protect your legal right to work and reside in Thailand, ensuring a smooth and uninterrupted employment experience.

Renewal of Thailand Work Permit: What You Need to Know

Renewing your Thailand work permit is a critical step to continue working legally without interruption. The renewal process should begin well before your current work permit expires. Typically, you will need to submit your renewal application to the Labor Department, along with all required documents. These include your valid passport, a recent medical certificate from a recognized Thai hospital, and updated corporate documents from your employer, such as business registration and tax filings.

It is important to coordinate the renewal of your work permit with the extension of your Non Immigrant B visa. Your visa must be valid for the entire period you are seeking to renew your work permit. If your visa is close to expiring, apply for a visa extension at the immigration office before submitting your work permit renewal.

The Labor Department may request additional information or documents during the review process, so it is wise to prepare all paperwork in advance and consult with your employer or a qualified immigration consultant. Processing times can vary from a few days to several weeks, depending on your location and the complexity of your case. Staying proactive and organized will help ensure your work permit renewal is approved smoothly, allowing you to continue your employment in Thailand without legal issues.

Violations and Penalties for Non Compliance with Work Permit Rules

Strict compliance with Thailand’s work permit regulations is essential for all foreign workers and their employers. Working without a valid work permit, engaging in activities not specified in your job description, or failing to report changes in address or employment to the Immigration Bureau are serious violations. Such infractions can result in heavy fines, imprisonment, and even deportation.

Employers who hire foreign workers without proper work permits also face significant penalties, including fines and possible jail time. Fines for non compliance can range from 1,000 to 100,000 THB, and imprisonment can extend from several months to several years, depending on the severity of the violation. In addition, foreign workers found in violation may be blacklisted, making it difficult or impossible to obtain future work permits or visas for Thailand.

To avoid these consequences, foreign workers must ensure they always have a valid work permit, comply with all reporting requirements to the Immigration Bureau, and only perform work authorized under their permit. Employers should regularly audit their compliance with labor and immigration laws to protect both their business and their foreign employees. Understanding and following these rules is the best way to ensure a successful and trouble free work experience in Thailand.

Conclusion

Obtaining a work permit in Thailand is more than just a personal requirement: it is a comprehensive system of business compliance. Success depends on the health of the sponsoring company and the precision of the documentation provided. By understanding that the process is employer driven and following a strict strategic sequence you can navigate the bureaucracy effectively. Use this checklist and focus on employer compliance to significantly increase your chances of a smooth approval.

You might also like: A Complete Guide to Thailand’s Construction Bidding Process for Contractors and Investors

Issued: 15 December 2025

Effective: 15 December 2025 (for the 2025 CIT assessment period)

On 15 December 2025, the Vietnamese Government issued Decree 320/2025/ND-CP, providing detailed guidance on the implementation of the 2025 Corporate Income Tax (CIT) Law. This decree marks a comprehensive modernization of Vietnam’s CIT framework, clarifying rules on deductible expenses, research and development incentives, corporate tax rates, foreign enterprise obligations, capital transfers, and transitional provisions. It also addresses compliance challenges in a rapidly digitalizing and globally integrated business environment. Enterprises operating in Vietnam, including both domestic and foreign-invested companies, must carefully review these provisions to ensure compliance, optimize tax planning, and avoid potential penalties.

Conditions for Deductible Expenses (Article 9)

A key focus of Decree 320 is the clarification of conditions under which expenses are deductible for CIT purposes. To qualify, an expense must meet all three of the following criteria:

• Business-related: The expense must be genuinely incurred and directly associated with the enterprise’s production or business operations. Only costs that are necessary and appropriate for the conduct of business are eligible.

• Proper documentation: The expense must be supported by valid invoices and other supporting documents as required under Vietnamese accounting and tax regulations.

• Non-cash payments for high-value transactions: For any single transaction valued at VND 5 million or more, non-cash payment documentation is required. This includes payments via bank transfers, credit cards, or other cashless methods recognized by law.

Important Note: This represents a substantial reduction from the previous threshold of VND 20 million under Decree 218, reflecting the government’s effort to encourage transparency and align taxation with modern payment methods.

The decree further clarifies the treatment of unpaid transactions exceeding VND 5 million. Enterprises may include such expenses as deductible when determining taxable income, even if payment has not yet occurred, provided that all other conditions are satisfied. However, if payment is later made without non-cash documentation, the expense must be adjusted downward in the tax period in which the payment occurs. Notably, these rules apply even in cases where a tax audit or inspection decision has been issued, reinforcing the importance of maintaining proper payment documentation and accounting records.

Research and Development (R&D) Expenses

Decree 320 also maintains robust incentives for research and development activities, reflecting the government’s focus on innovation-driven growth. Eligible R&D expenditures are deductible for CIT purposes up to 200% of actual expenses, subject to the following conditions:

• The R&D activities must fall within the scope defined by Vietnam’s laws on science, technology, and innovation.
• Proper invoices and supporting documentation must be maintained.
• The additional deduction must not result in a tax loss for the enterprise, ensuring that claimed deductions are sustainable and do not undermine the financial position of the business.

By providing a substantial enhancement to R&D deductions, the decree encourages enterprises to invest in innovation and technological development while safeguarding fiscal integrity.

Corporate Income Tax Rates (Article 11)

Decree 320 prescribes differentiated corporate income tax rates based on total annual revenue, creating incentives for smaller businesses while maintaining a standard rate for larger enterprises. Total revenue includes sales (excluding revenue deductions), service income (excluding revenue deductions), financial income, and other income as reported in the appendix of business performance results.

Total Annual Revenue	CIT Rate
≤ VND 3 billion	15%
> VND 3 billion to ≤ VND 50 billion	17%
> VND 50 billion	20%

Note: The preferential 15% and 17% rates do not apply to subsidiaries or affiliated companies if the entity does not meet the eligibility conditions, emphasizing careful revenue assessment and planning.

The decree also provides guidance on how to determine total revenue, including revenues from sales, services, financial activities, and other income streams. Accurate revenue reporting is essential to ensure the correct application of CIT rates and to avoid underpayment or disputes with tax authorities.

Foreign Enterprises and Expanded Withholding Responsibilities

Decree 320 introduces specific provisions for foreign enterprises operating in Vietnam. Companies established under foreign laws are subject to Vietnam CIT, regardless of having a permanent establishment (PE). The taxable income of foreign enterprises with a PE includes:

• Income earned both within and outside Vietnam attributable to the PE’s operations.
• Income generated in Vietnam that is not attributable to the PE.
• Income arising from supplying goods or services in Vietnam via e-commerce or digital platforms.

Foreign enterprises without a PE are subject to CIT only on income arising in Vietnam, aligning tax obligations with income-generating activities. Additionally, the decree expands the scope of entities responsible for withholding CIT on behalf of foreign enterprises. Vietnamese-registered entities that purchase goods or services, engage in e-commerce, or receive capital transfers from foreign enterprises are required to withhold and remit taxes, ensuring compliance across domestic and cross-border transactions.

Securities investment fund management companies are similarly treated as withholding agents for investors, particularly regarding profits distributed to investors and income arising from the transfer or lease of real estate.

Capital Transfer Taxation and Exclusions

Capital transfers in Vietnam are now taxed at a 2% rate under Decree 320. However, intra-group ownership restructuring transactions may be exempt if they do not change the ultimate parent company and do not generate taxable income. The decree also explicitly excludes certain income items from taxation, including:

• Income from share issuance and dividends (excluding dividends on liability-classified shares).

• Income from the sale of treasury or repurchased shares.

• Other income directly associated with changes in owners’ equity.

These provisions clarify ambiguities from previous regulations under Decree 218 and provide certainty for corporate restructuring and investment planning.

Income from Business Cooperation Contracts (BCCs)

Decree 320 expands taxable income to include revenue derived from business cooperation contracts. Taxable income under a BCC is calculated as total revenue under the contract minus direct costs. Profit-sharing mechanisms may include:

1. Revenue-based sharing: Each party declares revenue based on its allocated share.

2. Product-based sharing: Revenue is determined based on the value of products allocated to each party.

3. Pre-tax profit sharing: A designated representative issues invoices, records revenue and costs, and allocates pre-tax profit, with each party fulfilling CIT obligations independently.

4. Post-tax profit sharing: A designated representative declares and pays CIT on behalf of all participating parties.

CIT-Exempt Income and Incentives

Decree 320 expands CIT exemptions to include income derived from technical services directly supporting agricultural activities, such as flood drainage, tidal and salinity control, desalination, and acid sulfate soil treatment. Additionally, income from products using technology applied for the first time in Vietnam is eligible for a three-year CIT exemption, a reduction from the previous maximum of five years. Certification by a competent authority is required to confirm that the technology is genuinely new to Vietnam.

Non-Cash Payment Threshold and Compliance Measures

A key practical measure is the lowered non-cash payment threshold for deductible expenses, set at VND 5 million. Enterprises should note that:

• Multiple purchases from the same supplier totaling VND 5 million or more in a single day require non-cash payment documentation to be deductible.

• Expenses incurred by employees and reimbursed via non-cash methods are deductible if supported by proper invoices and internal authorization.

Expenses recorded before payment may be provisionally deducted, but adjustments are required if cash payment occurs later, even after tax audits.

Transitional Provisions

Decree 320 provides transitional rules to facilitate compliance. Existing tax incentives for approved projects may continue for the remaining period, and more favorable provisions under Decree 320 can be applied. Tax losses incurred prior to the decree’s effective date may be carried forward, with exceptions for real estate and investment project losses. Income streams that no longer qualify for incentives will cease to enjoy benefits from the effective date.

Practical Implications for Enterprises

Businesses, especially foreign-invested enterprises, digital platform operators, and groups involved in capital transfers, should take proactive measures to comply and optimize tax positions:

• Review taxpayer and withholding positions: Assess whether your entity is now considered a taxpayer or withholding agent.
• Update accounting and payment systems: Ensure compliance with the VND 5 million non-cash payment threshold.
• Assess R&D and incentive opportunities: Verify eligibility for deductions and CIT exemptions.
• Plan capital transfers and restructuring: Evaluate exposure to the 2% tax and ensure documentation for exemptions.

Conclusion

Decree 320/2025/ND-CP represents a comprehensive modernization of Vietnam’s corporate income tax system. By clarifying deductible expenses, lowering non-cash payment thresholds, detailing R&D incentives, specifying corporate tax rates, and expanding rules for foreign enterprises and capital transfers, the decree aligns tax regulations with the realities of a digital, integrated, and innovation-driven economy. Enterprises operating in Vietnam must carefully review internal processes, update documentation systems, and strategically plan transactions and investments to ensure full compliance and take advantage of available incentives.

Effective from 1 July 2026

The Amended Law on Personal Income Tax (“Amended PIT Law”) represents a substantive reform of Vietnam’s personal income tax framework, responding to long-standing structural issues and emerging challenges arising from digitalisation, income growth, and rising living costs. Effective from 1 July 2026, with certain provisions applicable earlier from 1 January 2026, the amendments recalibrate tax brackets, expand taxable income categories, and revise deduction principles to enhance equity, transparency, and administrative efficiency.

For enterprises operating in Vietnam, including foreign-invested enterprises (FIEs), the amendments will have practical implications for payroll administration, withholding obligations, employee tax planning, and internal compliance systems. For individuals, particularly those earning income from digital platforms or multiple sources, the new rules signal a broader tax base and increased reporting expectations.

This article outlines the key changes under the Amended PIT Law, explains their policy rationale, and highlights tax implications and practical considerations for enterprises and individuals registered in Vietnam.

Policy Context and Legislative Rationale

Vietnam’s existing PIT framework has been under increasing strain in recent years. While nominal income levels have risen significantly, personal and dependent deductions have not kept pace with inflation or living costs. At the same time, the structure of the progressive tax brackets (with seven relatively narrow tiers) has contributed to complexity in payroll administration and taxpayer understanding.

In parallel, the rapid expansion of the digital economy has blurred traditional distinctions between employment income, business income, and investment income. Revenue generated through e-commerce platforms, social media, and digital assets has grown substantially, yet enforcement mechanisms under the existing PIT regime have remained limited.

Against this backdrop, the Amended PIT Law pursues three core objectives: simplifying the rate structure, broadening the tax base to include emerging income streams, and recalibrating deductions to better reflect economic realities. These changes align with Vietnam’s broader tax reform agenda and its efforts to modernise tax administration through data integration and digital oversight.

Simplification of the Progressive Tax Rate Structure

Transition from Seven to Five Tax Brackets

A central feature of the Amended PIT Law is the simplification of the progressive tax rate structure applicable to salary, wage, and business income. The number of tax brackets is reduced from seven to five, while maintaining the lowest marginal rate of 5 per cent and the highest marginal rate of 35 per cent.

This restructuring is intended to improve transparency and ease administration without fundamentally altering Vietnam’s progressive taxation principles. By widening the income bands within each bracket, the new structure reduces sharp marginal jumps and provides greater predictability for taxpayers.

Increase in the Highest-Bracket Threshold

In addition to reducing the number of brackets, the Amended PIT Law raises the income threshold at which the highest marginal rate applies. Under the revised regime, the 35 per cent rate applies only to monthly taxable income exceeding VND 100 million, compared to the current threshold of VND 80 million.

This adjustment reflects income growth over time and mitigates “bracket creep,” particularly for professionals and senior employees whose earnings have increased due to inflation rather than real income gains.

Illustrative Comparison of PIT Brackets

The table below illustrates the structural change under the Amended PIT Law:

Tier	Taxable income per year (VND million)	Taxable income per month (VND million)	Amended PIT Law (5 tiers)
1	Up to 120	Up to 10	5%
2	Over 120 to 360	Over 10 to 30	10%
3	Over 360 to 720	Over 30 to 60	20%
4	Over 720 to 1,200	Over 60 to 100	30%
5	Over 1,200	Over 100	35%

While the headline rates remain unchanged, the consolidation of brackets alters the effective tax burden for certain income groups and simplifies payroll calculations.

Expansion of Taxable Income to the Digital Economy

Digital Platform and E-Commerce Income

The Amended PIT Law explicitly extends PIT coverage to income derived from digital platforms and e-commerce activities. This includes income earned through online marketplaces, ride-hailing and delivery platforms, content creation, online advertising, and other forms of digital monetisation.

By formally recognising these income streams as taxable, the law seeks to ensure neutrality between traditional and digital economic activities. This expansion also signals the tax authority’s intention to strengthen oversight through data sharing with platforms and payment intermediaries.

For individuals, this change increases the likelihood that income earned online, whether as a primary occupation or supplementary source, will be subject to PIT. For enterprises operating digital platforms, further guidance may introduce reporting or withholding obligations that affect operational models.

Digital Assets and Cryptocurrency Transactions

The Amended PIT Law also extends PIT coverage to certain digital asset transactions, including cryptocurrency trading. Although detailed rules are expected to be issued in subsequent guidance, the inclusion of digital assets reflects global trends toward taxing virtual asset gains and addressing base erosion risks.

Individuals engaged in digital asset trading should anticipate increased scrutiny and potential reporting obligations. Enterprises involved in blockchain, fintech, or related services should assess whether employee compensation or incentive schemes involving digital assets may give rise to PIT exposure.

Revision of Personal and Dependent Deduction Principles

The Amended Personal Income Tax Law revises family circumstance deductions to better reflect current living costs and income levels, while also introducing a more responsive mechanism for future adjustments.

Key changes to deduction levels

• Personal deduction: increased from VND 11 million (US$418) to VND 15.5 million (US$589) per month
• Dependent deduction: increased from VND 4.4 million (US$167) to VND 6.2 million (US$236) per dependent per month

Resulting PIT exemption thresholds

Family status	Monthly income not subject to PIT
No dependents	Up to VND 17 million
One dependent	Up to VND 24 million
Two dependents	Up to VND 31 million

Updated adjustment mechanism

• Under the current law, deduction levels may only be revised when the CPI increases by more than 20%, a threshold that has proven inflexible in practice.

• The Amended Law requires the Government to proactively submit adjustment proposals to the Standing Committee of the National Assembly when changes in prices and income levels warrant revision.

• This approach is intended to ensure that family circumstance deductions remain timely, practical, and aligned with economic conditions, rather than being adjusted only after prolonged inflationary periods.

Effective Dates and Transitional Issues

Although the Amended PIT Law formally takes effect on 1 July 2026, provisions relating to salary, wages, and business income will apply from 1 January 2026. This staggered implementation requires careful planning, particularly for payroll cycles and annual tax finalisation.

Enterprises should ensure that payroll systems are capable of applying the new rules from the beginning of the 2026 calendar year, even though the law itself takes effect mid-year.

Implications for Enterprises and Employers

For enterprises registered in Vietnam, the Amended PIT Law necessitates a review of payroll systems, internal controls, and compliance processes. Employers with large workforces may need to update payroll software, revise withholding calculations, and retrain HR and payroll personnel.

Foreign-invested enterprises should also reassess tax equalisation and gross-up arrangements for expatriate employees, as changes in deductions and bracket thresholds may affect net-of-tax outcomes.

In addition, enterprises engaging freelancers, digital contractors, or platform-based service providers should monitor forthcoming guidance to determine whether new withholding or reporting obligations apply.

Practical Considerations and Recommended Actions

To prepare for the implementation of the Amended PIT Law, enterprises and individuals may consider the following steps:

• Review payroll and HR systems to ensure timely updates for new tax brackets and deduction levels.
• Assess exposure to PIT on digital and platform-based income, particularly for employees with multiple income streams.
• Update internal tax policies and employee communications to reflect the revised PIT framework.
• Monitor implementing regulations for detailed guidance on digital income and asset taxation.
• Seek professional tax advice to manage transitional risks and ensure compliance.

Conclusion – Tax Implications and Advisory Perspective

The Amended Law on Personal Income Tax will materially reshape PIT obligations in Vietnam, with implications extending beyond individual taxpayers to employers and enterprises operating in the country. While increased deductions and a simplified rate structure provide relief for many employees, the expanded scope of taxable income (particularly in the digital economy) signals a more comprehensive and data-driven approach to tax enforcement.

For enterprises registered in Vietnam, including existing foreign firms, the amendments require proactive planning. Payroll systems must be updated in advance of the effective date, withholding practices reviewed, and internal controls strengthened to manage compliance risks. Companies employing digital workers or expatriates should pay particular attention to income characterisation and reporting obligations.

Early preparation and clear internal communication will be essential to ensure smooth implementation, minimize tax exposure, and maintain compliance under Vietnam’s evolving personal income tax framework.

Southeast Asia is entering a new infrastructure supercycle, but the pipeline emerging for the upcoming years proves uniquely strategic. Public investment in physical connectivity serves as a highly accurate proxy for long-term state commitment to economic modernization. The Thailand mega infrastructure investment 2026 pipeline represents more than just a massive surge in the construction sector; it stands as a directional signal for capital allocation, supply chain realignment, and foreign direct investment prioritization. Organizations navigating this landscape require deep regional expertise to interpret these macro-level shifts. Viettonkin Consulting's regional presence provides direct exposure to ASEAN investment flows and policy evolution, ensuring strategic market entry for global entities.

Key Points:
• The upcoming mega infrastructure pipeline indicates a structural economic transition rather than short-term stimulus spending.
• Enhanced transport and digital networks serve as critical foundations for positioning the nation as a primary China+1 manufacturing alternative.
• Massive mega projects like the Land Bridge and Eastern Economic Corridor are fundamentally reshaping regional logistics and capital flows.
• The most lucrative opportunities extend beyond primary construction into specialized supply chain integration and localized ecosystem services.
• Successful market entry requires distinguishing between fully approved projects and those vulnerable to political transition delays.

Why Thailand Mega Infrastructure Investment 2026 Signals a Structural Economic Shift

The scale of planned infrastructure spending and what it reveals for investors

Understanding the true implications of this supercycle requires examining the massive financial scope involved. With the total investment estimated reaching between THB 300 billion and over THB 1 trillion, these figures represent substantial long term budget commitments. For institutional investors, interpreting pipelines of this magnitude reveals a multi-year dedication to sustainable economic growth rather than temporary market interventions. In emerging ASEAN markets, infrastructure spending typically delivers a GDP multiplier of approximately 1.5–2.0x, generating broad macroeconomic benefits.

How to read government spending as investment signals

Determining true policy direction requires a systematic signal framework. Analysts evaluate policy credibility by examining budget allocation consistency and project continuity across different administrations. A critical metric involves comparing the ratio of public-private partnerships (PPP) to direct state funding, as heavy private involvement often indicates deeper commercial viability. When proposals undergo rigorous cabinet consideration and secure final cabinet approval, they transition from theoretical blueprints to actionable market indicators.

Why infrastructure investment is now tied to geopolitical supply chain shifts

For multinational corporations seeking resilient supply lines, the country is aggressively positioning itself as a premier China+1 alternative. In this context, advanced infrastructure does not merely support domestic market expansion; it functions as the critical foundation of export competitiveness. Integrating modernized digital infrastructure with physical supply routes ensures that domestic manufacturing hubs remain highly competitive within complex global trade networks.

Core Mega Projects Reshaping Thailand Economy and Investment Landscape

Transport infrastructure highways rail and logistics corridors driving industrial expansion

Enhancing Thailand's transport capabilities remains the primary driver of industrial expansion. For industrial investors, logistics cost reduction translates directly to margin expansion. Current logistics costs in Thailand account for roughly 13–15% of GDP, establishing a clear target for systemic reduction. To address this, Thailand's transport ministry has outlined extensive modernization plans. Critical aviation hubs are undergoing massive upgrades; the Suvarnabhumi Airport East Expansion and significant Don Mueang improvements will raise capacity substantially. These projects will boost both cargo handling and passenger capacity to support tourism and commercial operations alike. Concurrently, the expressway authority is executing vital highways projects, while widespread rail development will modernize national freight operations.

A deeper breakdown of priority corridors

Capital allocation heavily favors strategic geographic zones. According to the Bangkok Post (2025), land pricing in the Eastern Economic Corridor (EEC) surged significantly amid strong foreign demand, highlighting massive new activity and robust investor confidence. Cross-border connectivity relies equally on massive regional undertakings. According to further reporting from the Bangkok Post (2025), the Asian Infrastructure Investment Bank (AIIB) expressed profound interest in funding the monumental land bridge megaproject. This ambitious maritime bypass is structurally supported by legislative frameworks like the southern economic corridor act. Other critical transportation arteries include expansions to the Outer Bangkok Ring Road, upgrades to the ChaLong Rat expressway, and the proposed motorway route featuring the Pak Tho section advancing toward Cha Am.

Energy infrastructure and the transition toward industrial sustainability

Modern manufacturing demands robust and resilient power networks. For institutional investors, energy reliability directly dictates manufacturing viability. The current development pipeline integrates aggressive growth in renewable sources and massive grid upgrades, ensuring that the transition toward industrial sustainability meets stringent global compliance and ESG standards.

Urban development smart cities and real estate spillover effects

The expansion of transit networks naturally catalyzes widespread urban expansion. For real estate developers and institutional funds, secondary cities are transforming into lucrative investment hotspots. Connecting major industrial zones to urban areas like Chiang Mai via high speed rail and strategic junction development creates massive spillover effects. This infrastructure expansion drives immense demand for both commercial spaces and residential properties adjacent to new transit hubs.

Where the Real Investment Opportunities Are Emerging for FDI Players

Translating data into strategic sectors

While broad financial data outlines massive total investment figures, strategic players must translate these numbers into actionable target sectors. Core opportunities lie far beyond primary construction; they encompass specialized logistics, advanced construction materials, smart industrial real estate, and sophisticated energy distribution technologies.

Tier one opportunities direct infrastructure participation and PPP projects

For major institutional investors, tier-one opportunities involve direct participation in PPP structures and government-backed contracts. Securing long-term agreements with entities like the state railway involves navigating complex risk-return profile calculations. When a major phase of a core initiative is fully completed and approved, primary contractors secure decades-long, stable revenue streams.

Tier two opportunities supply chain and ecosystem plays

Multinational corporations can capture substantial value through tier-two ecosystem integration. Opportunities flourish for specialized component suppliers, sophisticated engineering services, and firms capable of complex technology integration. These sectors are expected to see exponential growth as primary mega-projects mobilize and require advanced technical support.

Hidden winners SMEs and localized service providers

Massive infrastructure spending creates multi-layer economic ripple effects throughout the economy. Localized service providers and specialized small-to-medium enterprises often emerge as the hidden winners of this supercycle. Unprecedented opportunities surface in legal consultation, regulatory compliance management, and strategic localization services required by incoming foreign entities.

Risks Constraints and Execution Realities Investors Must Understand

Real execution bottleneck analysis

Despite robust funding and ambitious targets, execution realities consistently present severe bottlenecks. Major projects are frequently delayed by bureaucratic friction, complex land acquisition negotiations, and prolonged feasibility studies. Understanding these realistic timelines prevents premature capital deployment and strategic misallocation.

Political uncertainty and its impact on project continuity

Navigating the market requires distinguishing between theoretical proposals and executable projects. A political transition inevitably impacts project continuity. During periods characterized by an election commission managing advance voting, or situations featuring an awaiting placement for a new government or new cabinet, the standard cabinet agenda often shifts or stalls. A transport ministry source might indicate the ministry believes a specific initiative is vital, but the cabinet secretariat may pause proceedings during administrative handovers. For instance, high-profile undertakings like the phuket expressway project depend heavily on maintaining momentum across changing administrations to secure required approvals from the prevailing cabinet.

Financing challenges and public private partnership limitations

Executing billion-dollar infrastructure mandates faces significant macroeconomic constraints. Elevated national debt levels limit the capacity for direct public funding, while stringent foreign participation barriers occasionally reduce the attractiveness of certain public-private partnership structures for international banking institutions.

Regulatory and legal complexity for foreign investors entering infrastructure sectors

For corporate legal directors and compliance officers, entering the infrastructure sector demands sophisticated legal strategies. Navigating strict local licensing requirements, managing sector-specific foreign ownership caps, and executing intricate compliance protocols remain mandatory hurdles for successful market penetration and sustained operations.

Transformative Insight Why Thailand Infrastructure Investment Is a Long Term Signal Not a Short Term Trend

Transformative insight one infrastructure spending is a leading indicator of industrial policy shifts

Market analysts must reframe how this spending is viewed: it represents proactive economic positioning rather than reactive fiscal stimulus.According to the World Bank (2026), Thailand's next phase of growth depends intrinsically on fostering industries of the future, a transition impossible without foundational transport and digital infrastructure modernization.

Transformative insight two mega projects redefine regional capital flows in Southeast Asia

The domestic market fiercely competes with regional peers like Vietnam and Indonesia for global capital. Monumental undertakings are explicitly designed to redefine Southeast Asian capital flows, cementing the nation as the premier, indispensable logistical hub for the broader ASEAN region.

Transformative insight three early movers capture ecosystem advantages not just project returns

The most significant financial rewards accrue to early movers who capture broad ecosystem advantages. Securing advantageous land positioning, establishing vital supply partnerships, and executing precise market entry strategies yield substantially higher long-term returns than waiting for final infrastructure pricing to stabilize post-completion.

Conclusion

Infrastructure spending is a leading indicator of industrial policy. The 2026 pipeline cements Thailand as an indispensable logistical hub for ASEAN. Early movers who secure land positions and supply partnerships now will capture significantly higher returns before infrastructure pricing stabilizes post-completion. Viettonkin Consulting remains a vital partner in this strategic landscape, supporting investors with crucial market intelligence, comprehensive FDI strategy, and expert legal and regulatory navigation across complex ASEAN markets.

Frequently Asked Questions

How long does it typically take for foreign investors to establish participation in these infrastructure initiatives?

Entering major public infrastructure initiatives typically requires a 12 to 24-month lead time for foreign entities. This extended period is necessary to navigate complex regulatory environments, form mandatory local joint ventures, complete extensive impact assessments, and participate in formal procurement bidding processes.

What distinguishes the current infrastructure pipeline from previous regional development plans?

The current pipeline represents a structural shift from purely domestic capacity building toward global supply chain integration. Unlike previous localized upgrades, major modern initiatives are explicitly designed to capture relocating global manufacturing and position the region as a primary alternative manufacturing hub.

How can specialized service providers capitalize on the upcoming megaproject developments?

Service providers can capture tremendous value by positioning themselves as specialized vendors to primary stakeholders. Key focus areas include providing localization consulting, localized legal compliance, environmental engineering assessments, and technology integration services, which experience high demand without requiring the massive capital outlays of direct project participation.

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Effective date: 15 October 2025

Applicable tax year: 2024 onwards

On 29 August 2025, the Vietnamese Government officially issued Decree No. 236/2025/ND-CP (“Decree 236”), providing detailed guidance on the implementation of the Global Minimum Tax (“GMT”) regime in Vietnam. This Decree follows Resolution No. 107/2023/QH15, dated 29 November 2023, which formally mandated Vietnam’s adoption of the Global Anti-Base Erosion (“GloBE”) rules in alignment with the OECD’s Pillar Two framework.

Decree 236 marks a significant milestone in Vietnam’s international tax reform agenda. Beyond introducing new compliance requirements, it fundamentally reshapes the principles of corporate income tax calculation for multinational enterprises (“MNEs”), particularly those with cross-border supply chains, related-party structures, and incentive-driven investment models. This article provides a consolidated overview of the Decree’s key provisions, highlights how it differs from Vietnam’s traditional corporate income tax framework, and outlines practical implications for enterprises operating in Vietnam, including existing foreign-invested companies.

Regulatory Background and OECD Recognition

Resolution 107 established Vietnam’s commitment to adopting the Global Minimum Tax framework, enabling the imposition of an additional corporate income tax to ensure that large multinational groups pay a minimum effective tax rate of 15 per cent on a jurisdictional basis. Decree 236 operationalises this commitment by setting out detailed rules, administrative procedures, and transitional measures governing Vietnam’s application of the GMT.

Importantly, as of August 2025, Vietnam’s Global Minimum Tax legislation has been recognised by the OECD Inclusive Framework on BEPS as achieving transitional qualified status. Both Vietnam’s Qualified Domestic Minimum Top-up Tax (QDMTT) and Income Inclusion Rule (IIR) frameworks are considered to meet the relevant international standards. In addition, Vietnam’s QDMTT qualifies for the QDMTT safe harbour mechanism, which is intended to reduce the risk of duplicative top-up taxation under foreign IIR regimes. This recognition enhances the predictability and coherence of Vietnam’s GMT implementation within the broader international tax landscape.

Identification of Additional Corporate Income Taxpayers (Article 3)

Under Article 3 of Decree 236, a Constituent Entity of a Multinational Enterprise is classified as an additional corporate income taxpayer for GMT purposes if the ultimate parent entity’s consolidated financial statements reflect annual global revenue of at least EUR 750 million in at least two of the four fiscal years immediately preceding the year in which the tax obligation arises.

This threshold aligns with the OECD GloBE rules and establishes the primary gateway for determining whether an MNE group falls within the scope of Vietnam’s GMT regime. Once the revenue threshold is met, relevant Vietnamese entities of the group, as well as certain overseas entities owned by Vietnamese parent entities, may be subject to additional corporate income tax under either the QDMTT or the IIR, depending on the structure and tax profile of the group.

Scope of Global Minimum Tax Application in Vietnam

Decree 236 provides detailed guidance on the application of the Global Minimum Tax through two principal mechanisms: the Qualified Domestic Minimum Top-up Tax (QDMTT) and the Income Inclusion Rule (IIR). While both mechanisms are designed to ensure a minimum effective tax rate of 15 per cent, they differ in scope, function, and taxing priority.

Scope comparison of QDMTT and IIR under Decree 236

Criteria	QDMTT	IIR
Policy objective	Ensure Vietnam retains taxing rights over low-taxed domestic profits	Tax low-taxed foreign profits through Vietnamese parent entities
Nature of tax	Domestic top-up tax	Cross-border inclusion mechanism
MNE revenue threshold	EUR 750 million or more in at least two of the four preceding fiscal years	Same threshold applies
Entities in scope	Vietnamese Constituent Entities of in-scope MNEs, including Constituent Entities, joint ventures and JV subsidiaries, and permanent establishments (excluding stateless entities)	Overseas Constituent Entities, joint ventures, JV subsidiaries, permanent establishments, and certain investment entities owned by Vietnamese Ultimate, Intermediate, or Partially Owned Parent Entities
Trigger for application	Vietnamese jurisdictional effective tax rate below 15%	Overseas jurisdictional effective tax rate below 15%
Tax base	Income generated in Vietnam	Foreign income of overseas Constituent Entities
Priority within GMT framework	Takes precedence over IIR for Vietnamese profits	Applies after QDMTT in the source jurisdiction
Initial-phase exclusion	QDMTT may be deemed nil where the MNE operates in no more than six jurisdictions and overseas tangible assets do not exceed EUR 50 million	Not applicable
Transitional relief	Transitional safe harbours and de minimis thresholds may apply based on Country-by-Country Reporting data	Transitional safe harbours may apply under GloBE rules

Initial Phase Exclusion and Transitional Relief Measures

To ease the compliance burden during the early stages of GMT implementation, Decree 236 introduces an initial-phase exclusion for QDMTT. Under this provision, Vietnam’s QDMTT liability may be deemed nil for a qualifying MNE group where both of the following conditions are met:

• The MNE group operates Constituent Entities in no more than six jurisdictions; and
• The total book value of tangible assets located outside the reference jurisdiction does not exceed EUR 50 million.

This exclusion applies for up to five fiscal years starting from the first year in which the MNE group falls within the scope of the GloBE rules. The reference jurisdiction is determined based on the jurisdiction in which the group holds the highest total value of tangible assets in that initial year.

In addition, Decree 236 incorporates transitional and de minimis relief measures aligned with OECD guidance. These include simplified effective tax rate tests and profit thresholds based on Country-by-Country Reporting (CbCR) data, which may allow jurisdictional top-up tax to be treated as nil during the transitional period, subject to specified conditions.

Income Inclusion Rule and Ordering Mechanism

The IIR under Decree 236 applies where a Vietnamese entity acts as an ultimate parent entity, partially owned parent entity, or intermediate parent entity that directly owns overseas Constituent Entities subject to low effective tax rates. In such cases, Vietnam may impose top-up tax on the foreign income of those overseas entities to bring the overall effective tax rate up to the global minimum of 15 per cent.

Decree 236 confirms the application of the IIR ordering rule in line with OECD standards. Under this rule, top-up tax is applied sequentially along the ownership chain, beginning with the ultimate parent entity, followed by partially owned parent entities, and then intermediate parent entities. This ordering mechanism ensures that top-up tax is collected at the highest appropriate level within the group structure and avoids duplication.

Tax Payment, Offsetting, and Refund Mechanisms (Clause 7, Article 16)

Additional corporate income tax arising under the Global Minimum Tax framework is payable to the central state budget. The relevant Constituent Entity is responsible for declaring and paying the additional tax in full compliance with Vietnam’s tax administration laws.

Where a Constituent Entity overpays additional corporate income tax, late payment interest, or administrative penalties under the GloBE regulations, Decree 236 provides three mechanisms for resolving the excess amount:

• Offsetting against outstanding tax liabilities or other amounts payable to the tax authority;
• Carrying forward the excess amount to offset tax obligations in subsequent periods; or
• Refunding the excess amount once the entity has fully settled all tax liabilities, late payment interest, and penalties.

These provisions introduce greater flexibility in managing overpayments and align the GMT regime with existing tax administration principles in Vietnam.

Implications for Corporate Tax Compliance

Decree 236 fundamentally reshapes the framework for corporate income tax calculation for large multinational groups, particularly those with cross-border operations, related-party transactions, or complex supply chains. The introduction of jurisdictional effective tax rate testing, group-wide revenue thresholds, and consolidated reporting requirements necessitates a reassessment of existing tax reporting processes and internal controls.

With retroactive application from the 2024 fiscal year and recognition under the OECD Inclusive Framework, Decree 236 signals Vietnam’s firm commitment to international tax reform while preserving domestic taxing rights. Multinational enterprises with operations in or from Vietnam will need to carefully monitor developments, assess their exposure under both QDMTT and IIR, and ensure timely compliance with the evolving Global Minimum Tax regime.

Conclusion

Decree No. 236/2025/ND-CP introduces significant changes to Vietnam’s corporate income tax framework by formally implementing the Global Minimum Tax in accordance with OECD Pillar Two principles. Enterprises operating in Vietnam that are part of multinational groups meeting the EUR 750 million revenue threshold may now face additional corporate income tax where their effective tax rate falls below 15 per cent, regardless of existing tax incentives or preferential regimes.

For Vietnamese constituent entities, this development requires a reassessment of current tax positions, incentive benefits, and group tax planning strategies. Foreign-invested enterprises should also anticipate increased compliance obligations, including detailed registration, filing, and reporting requirements linked to consolidated group financial data. Early coordination with group headquarters, timely preparation of required filings, and proactive review of effective tax rates will be critical to managing compliance risks and avoiding unexpected top-up tax exposures under the new regime.

Circular No. 32/2025/TT-BTC represents a further refinement of Vietnam’s electronic invoice regulatory framework, reinforcing the Government’s broader objectives of strengthening tax administration, improving transparency, and mitigating risks associated with invoice misuse. Issued against the backdrop of increased digitalization of tax compliance and the rapid expansion of e-commerce and digital business models, the Circular introduces targeted amendments that affect authorization arrangements, invoice identification standards, and the classification of high-risk taxpayers during electronic invoice registration.

Although Circular 32 does not fundamentally restructure the electronic invoice system established under Decree 123/2020/NĐ-CP and its guiding instruments, it introduces important clarifications and additional compliance layers. These changes reflect the tax authority’s increasing reliance on centralized data, cross-agency information sharing, and risk-based supervision to detect and prevent tax evasion, invoice trading, and other non-compliant practices.

For enterprises operating in Vietnam, including domestic companies, foreign-invested enterprises, and cross-border service providers, Circular 32 has direct operational, governance, and tax compliance implications. Businesses are therefore advised to review their invoicing arrangements and internal control frameworks to ensure continued compliance under the updated regulatory landscape.

Authorization for Third Parties to Issue Electronic Invoices

One of the key areas addressed by Circular 32 is the authorization of third parties to issue electronic invoices on behalf of taxpayers. This provision reflects the growing prevalence of outsourced invoicing models, particularly among enterprises using centralized accounting services, digital platforms, or integrated e-commerce systems.

Under Article 4, taxpayers are permitted to authorize a third party to issue electronic invoices, provided that the authorized entity is legally eligible to use electronic invoices and is not subject to any suspension of electronic invoice issuance under tax regulations. This requirement emphasizes that authorization is conditional upon the compliance status of the authorized party and must be assessed not only at the time of authorization but throughout the duration of the arrangement.

The Circular requires that such authorization be made in writing, reinforcing the importance of formal documentation. From a compliance standpoint, written authorization serves as evidence of lawful delegation and provides a clear basis for determining responsibilities in the event of tax inspections, audits, or disputes. Informal or implied authorization arrangements may not be sufficient to demonstrate compliance.

In addition to documenting the authorization, taxpayers must notify the tax authority when registering for electronic invoice usage. This notification requirement allows tax authorities to maintain visibility over invoicing structures and incorporate such information into their risk management systems. It also enables the tax authority to assess whether authorization arrangements are consistent with the taxpayer’s business model and transaction profile.

Circular 32 further introduces a transparency requirement toward buyers of goods and services. Both the authorizing taxpayer and the authorized third party must publicly disclose the authorization arrangement, either through their websites or via mass media channels. This measure aims to enhance trust in electronic invoices and reduce disputes over invoice validity, particularly in cases where invoices are issued by entities other than the contractual seller.

From a practical perspective, enterprises should review existing authorization agreements to ensure that they meet the formal requirements under Circular 32. Businesses should also establish procedures to monitor the compliance status of authorized third parties on an ongoing basis, as any suspension or violation affecting the third party could invalidate issued invoices and expose the taxpayer to tax and administrative risks.

Invoice Numbering, Symbols, and Invoice Series Identification

Circular 32 also introduces refinements to the rules governing invoice numbering, symbols, and series names, reflecting the increasing complexity of electronic invoice usage and the integration of invoices with tax, fee, and charge collection systems.

Article 5 requires electronic invoices to include specific numerical symbols that reflect the type and purpose of the invoice. Newly introduced symbols include:

• “7” to identify electronic invoices used in e-commerce transactions;

• “8” to identify value-added tax invoices integrated with receipts for taxes, fees, and charges; and

• “9” to identify sales invoices integrated with similar receipts.

In addition to numerical symbols, the Circular requires the inclusion of alphabetic characters to indicate invoice types. In particular, the letter “X” is designated for e-commerce invoices. These identifiers enhance the tax authority’s ability to classify invoice data accurately, conduct sector-based analysis, and identify unusual transaction patterns.

The revised requirements have significant implications for enterprises’ invoicing systems and internal processes. Incorrect invoice symbols or series identification may result in invoices being considered improperly issued, which could affect VAT deduction eligibility, corporate income tax deductibility of expenses, and the validity of accounting records.

Enterprises should therefore work closely with accounting teams and electronic invoice service providers to ensure that invoice templates, system settings, and automated workflows are updated in line with Circular 32. Adequate testing and internal training should be conducted to minimize errors during implementation, particularly for businesses issuing large volumes of invoices or operating multiple invoicing models.

Identification of High-Risk Taxpayers in Electronic Invoice Registration

Circular No. 32/2025/TT-BTC expands the criteria used by tax authorities to identify taxpayers considered high-risk when registering for electronic invoice usage. These criteria focus on ownership, management background, business location, and overall compliance profile, reflecting Vietnam’s increasing adoption of a risk-based tax administration approach.

First, a taxpayer may be classified as high-risk where its owner or legal representative has been determined by a competent authority to have previously engaged in fraudulent activities, including invoice trading or serious tax violations. Even where the enterprise itself has no prior non-compliance history, the personal compliance record of key individuals may affect the assessment.

Second, high-risk classification may apply if the owner or legal representative appears on the suspicious transaction list under the Law on Prevention and Combating Money Laundering. This criterion highlights the linkage between tax administration and anti-money laundering controls and may trigger enhanced scrutiny during the electronic invoice registration process.

Third, risks may arise from deficiencies in registered business addresses. Enterprises may be classified as high-risk where the head office address is unclear, not physically verifiable, located in residential premises not approved for business use, or where business activities are conducted outside the province or city of registration without proper updates.

Fourth, tax authorities may assess whether the owner or legal representative concurrently holds management roles in other enterprises that have ceased operations without completing tax code termination procedures, are not operating at their registered addresses, or have committed tax or invoice violations. Such circumstances may indicate elevated compliance risk.

Finally, tax authorities retain the discretion to apply additional risk indicators identified through supervisory experience or data analysis. In such cases, taxpayers must be notified and given the opportunity to provide explanations or supporting documentation before a final risk determination is made.

Tax and Compliance Implications for Enterprises in Vietnam

Circular 32 reinforces the importance of strong internal controls and compliance governance in electronic invoicing. Enterprises should view the Circular as part of a broader regulatory trend toward tighter oversight, increased transparency, and enhanced accountability in tax administration.

For enterprises authorizing third parties to issue invoices, clear documentation and ongoing monitoring are essential to mitigate risks associated with invoice invalidation. Businesses engaged in e-commerce or digital services should pay particular attention to invoice identification requirements, as these sectors are likely to remain a focus of tax authority supervision.

Foreign-invested enterprises should also consider the implications of cross-entity governance structures, especially where legal representatives or owners hold positions in multiple entities. Consistency in registration information and compliance history across entities can help reduce the risk of adverse classification.

Conclusion

Circular No. 32/2025/TT-BTC represents a targeted but meaningful enhancement of Vietnam’s electronic invoice regime. By clarifying authorization mechanisms, refining invoice identification standards, and expanding risk-based supervision criteria, the Circular supports the tax authority’s objective of strengthening compliance while accommodating evolving business practices.

Enterprises operating in Vietnam are advised to conduct a timely review of their invoicing arrangements, internal controls, and compliance processes to ensure alignment with the Circular’s requirements. Proactive preparation and careful implementation will be critical to minimizing operational disruptions and managing tax risks in an increasingly digital regulatory environment

Effective date: 1 January 2026

Circular No. 99/2025/TT-BTC introduces a series of important amendments to Vietnam’s accounting framework, marking another step in the Ministry of Finance’s efforts to modernize financial reporting, strengthen corporate governance, and enhance the transparency and reliability of accounting information. The Circular does not merely revise technical accounting forms; rather, it reshapes how enterprises prepare, authorize, present, and manage accounting records and financial statements.

These changes will affect enterprises across sectors, particularly those with complex internal structures, foreign-invested capital, or cross-border operations. As the effective date approaches, businesses should proactively assess the implications of the Circular on their accounting systems, internal control mechanisms, and compliance practices to ensure a smooth transition.

Preparation, Signing, and Control of Accounting Documents

One of the core focuses of Circular 99 is the reinforcement of discipline in the preparation and management of accounting documents. Accounting vouchers remain the legal foundation of all accounting records, and the Circular emphasizes stricter adherence to fundamental principles governing their use.

Mandatory Documentation of All Transactions

Under Circular 99, all economic and financial transactions arising from business operations must be documented using accounting vouchers, and each transaction may only be documented once. This principle, while not entirely new, is reaffirmed to address ongoing risks related to duplicate recording, incomplete documentation, or inconsistent transaction recognition across departments.

For enterprises with decentralized accounting functions or multiple operational units, this requirement underscores the importance of standardized procedures and clear communication between departments. Transactions involving procurement, sales, asset transfers, and internal cost allocations should be clearly traceable from source documents through to accounting records and financial statements.

Delegation of Signing Authority

The Circular also clarifies that the delegation of signing authority on accounting documents must strictly comply with:

• Relevant legal regulations
• Internal management requirements
• Internal governance and authorization rules of the enterprise

This provision highlights that delegation cannot be informal or implied. Enterprises are expected to have clear, documented authorization frameworks that specify who may sign which types of accounting documents and under what conditions.

In practice, this means enterprises should review existing authorization matrices, internal regulations, and powers of attorney to ensure consistency with legal requirements. Any ambiguity in signing authority may expose enterprises to compliance risks, particularly during tax audits or inspections by competent authorities.

Restrictions on the Chief Accountant’s Authority

A notable clarification under Circular 99 is that the chief accountant (or a person authorized by the chief accountant) is not permitted to sign on behalf of the enterprise’s legal representative, director, or manager on accounting documents.

This provision reinforces the separation of duties between management and accounting functions. While the chief accountant plays a critical role in ensuring the accuracy and compliance of financial records, decision-making authority and legal responsibility remain with the enterprise’s management.

Enterprises should carefully reassess internal practices where chief accountants may have historically signed documents beyond their formal authority, particularly in small or medium-sized enterprises. Adjustments to workflows and approval processes may be necessary to align with the Circular’s requirements.

Transition from Balance Sheet to Statement of Financial Position

From 1 January 2026, the traditional Balance Sheet will be formally replaced by the Statement of Financial Position, using Form B01-DN – Financial Statements.

This change reflects Vietnam’s gradual alignment with internationally recognized accounting terminology and concepts. While the substance of the information presented remains largely unchanged, the revised format emphasizes a more structured and conceptually consistent presentation of an enterprise’s financial position.

Practical Impact on Enterprises

The transition will require enterprises to update:

• Financial statement templates
• Accounting software and reporting systems
• Internal reporting manuals and training materials

For enterprises that prepare consolidated financial statements or report to overseas parent companies, the adoption of the Statement of Financial Position may improve comparability. However, careful attention will still be required during the transition period to ensure consistency between statutory financial statements and management or group reporting.

Revised Classification of Assets and Liabilities

Circular 99 introduces clearer guidance on the classification and presentation of assets and liabilities on the Statement of Financial Position.

Current and Non-Current Presentation

Assets and liabilities must be presented as current or non-current, with items arranged in decreasing order of liquidity. This approach enhances the usefulness of financial statements by providing stakeholders with clearer insights into an enterprise’s liquidity position and short-term solvency.

While many enterprises already follow similar principles, the Circular elevates this practice to a mandatory requirement, increasing expectations around consistency and accuracy.

Areas Requiring Careful Review

Enterprises should pay close attention to the classification of:

• Long-term receivables and payables
• Advances, deposits, and prepaid expenses
• Long-term provisions and contingent liabilities

Incorrect classification may distort key financial ratios and could lead to misunderstandings regarding an enterprise’s financial health. A thorough review of account mappings and financial statement disclosures will therefore be essential ahead of implementation.

Currency Units in Accounting

Circular 99 provides more detailed guidance on the use of foreign currencies as accounting units, an area of particular relevance to foreign-invested enterprises and companies engaged in international trade.

Conditions for Using a Foreign Currency

An enterprise may use a foreign currency as its accounting unit only if it satisfies conditions relating to:

• Revenue structure
• Expense composition
• Capital mobilization

These conditions aim to ensure that the chosen accounting currency reflects the enterprise’s economic reality rather than convenience. Enterprises that do not meet these criteria must continue to use Vietnamese Dong as their accounting currency.

Change of Accounting Currency

Where a change in accounting currency is permitted, it must:

• Be implemented at the beginning of an accounting period
• Apply the average exchange rate of the bank regularly used for transactions

This requirement prevents mid-period currency changes that could complicate financial reporting and reduce comparability.

Reporting Obligations

Regardless of the accounting currency used internally, financial statements must still be submitted in Vietnamese Dong. This ensures consistency for regulatory oversight, tax administration, and statistical purposes.

Enterprises using foreign currencies should ensure that their accounting systems can support accurate currency conversion, documentation of exchange rates, and reconciliation between accounting records and statutory financial statements.

Changes to the Accounting Chart of Accounts and Global Minimum Tax

One of the most forward-looking changes introduced by Circular 99 relates to the accounting treatment of Global Minimum Tax (GMT) obligations.

Separation of Account 821

Account 821 is now divided into:

• 82111 – Current corporate income tax expense under the Corporate Income Tax Law
• 82112 – Additional corporate income tax expense under Global Minimum Tax regulations (15%)

This separation reflects Vietnam’s implementation of international tax reforms and ensures clearer identification and tracking of different tax components.

Implications for Enterprises

The revised chart of accounts allows enterprises to:

• Monitor standard CIT liabilities separately from GMT top-up tax
• Improve transparency in tax expense reporting
• Facilitate compliance with both domestic and international tax reporting requirements

Multinational enterprises, in particular, should assess whether their accounting systems and internal reporting structures are capable of supporting this distinction and whether additional controls or disclosures may be required.

Governance, Systems, and Compliance Considerations

Taken as a whole, Circular 99 has implications that extend beyond accounting entries and financial statement formats.

Strengthening Internal Controls

The stricter rules on documentation, authorization, and signing authority will likely prompt enterprises to reassess their internal control frameworks. Clear segregation of duties, well-documented approval processes, and regular internal reviews will be critical to ensuring compliance.

System and Process Readiness

Enterprises may need to update accounting software, reporting tools, and internal manuals to reflect:

• New financial statement formats
• Revised chart of accounts
• Enhanced currency management requirements

Early preparation and cross-functional coordination will be essential to avoid operational disruptions when the Circular takes effect.

Conclusion

Circular No. 99/2025/TT-BTC represents a comprehensive and meaningful reform of Vietnam’s accounting and financial reporting framework. By strengthening rules on accounting documentation, governance, financial statement presentation, currency usage, and tax accounting, the Circular supports greater transparency, consistency, and alignment with international practices.

Enterprises are strongly encouraged to begin reviewing their accounting policies, internal controls, and reporting systems well in advance of the 1 January 2026 effective date. Early preparation will help mitigate compliance risks and ensure a smooth transition under the new regulatory framework

Effective Date: 01 July, 2025 

Effective from 1 July 2025, Vietnam introduces a set of important changes to its Value Added Tax (“VAT”) framework through Decree 181/2025/NĐ-CP and the guiding Circular 69/2025/TT-BTC issued by the Ministry of Finance. These regulations collectively refine VAT calculation methods, clarify refund eligibility, tighten input VAT deduction conditions, and provide more detailed guidance on transactions involving foreign parties and export activities.

Taken together, the Decree and the Circular reflect the Government’s ongoing efforts to enhance tax transparency, reduce ambiguity in VAT application, and strengthen compliance management in the context of increasing cross-border transactions and digitalised business models. Enterprises operating in Vietnam, including foreign-invested companies, should review these changes carefully to ensure timely and accurate implementation.

Refinement of VAT Calculation Based on Percentage Method

One of the key areas addressed under the new regulations concerns the VAT calculation method based on a percentage of revenue, which continues to apply primarily to business households, individuals, and certain entities not adopting the credit-invoice method.

Circular 69 introduces Appendix I, which clearly categorises activities subject to different percentage rates. Notably, the regulations distinguish between trading activities and service provision, while also clarifying the treatment of ancillary commercial activities such as sales incentives and customer support.

Applicable VAT Rates under the Percentage Method

VAT Rate	Applicable Activities
1%	Wholesale and retail trading (excluding agency sales at fixed prices earning commission); sales bonuses, trade discounts, and customer support activities
5%	Fifteen groups of services, including legal consulting, accounting, auditing, and other professional services

Compared to prior guidance, the new framework offers greater clarity by explicitly listing service categories subject to the higher 5% rate. This distinction reflects the tax authority’s intention to better align VAT treatment with the value-added nature of professional and consultancy services, which typically involve higher margins and lower input VAT.

For enterprises transitioning between calculation methods or engaging mixed activities, careful classification of revenue streams will be essential to avoid misapplication of VAT rates and potential reassessments.

Enhanced VAT Refund Mechanism

VAT Refunds for Exported Goods

Decree 181 and Circular 69 reaffirm the principle that exported goods are eligible for VAT refunds, while introducing a more substance-based approach to determining refundable amounts. Under Appendix II, the refundable VAT must now be calculated based on the actual export ratio, rather than purely on declared figures.

This change aims to address past risks where refunds were claimed disproportionately to actual export volumes. Export-oriented enterprises should therefore ensure that customs declarations, logistics records, and sales documentation are consistent and traceable.

VAT Refunds for Goods and Services Subject to 5% VAT

For enterprises producing goods or providing services subject to the 5% VAT rate, Appendix III introduces a clearer refund threshold. VAT refunds may be claimed where the undeducted input VAT reaches at least VND 300 million after a continuous 12-month period.

This provision provides greater predictability for businesses with long production or service cycles, particularly in sectors where input VAT accumulation is significant but output VAT remains low. At the same time, it discourages fragmented or short-term refund claims, aligning with administrative efficiency objectives.

Documentation Requirements for VAT Paid on Behalf of Foreign Suppliers

A notable compliance-related clarification concerns Vietnamese organizations that pay VAT on behalf of foreign suppliers without a permanent establishment in Vietnam, commonly encountered in cross-border service arrangements.

Under the new rules, input VAT deduction is only permitted if the Vietnamese payer holds valid tax payment documents evidencing the tax paid on behalf of the foreign supplier. This reinforces the tax authority’s focus on documentation integrity in foreign contractor tax arrangements.

Enterprises engaging overseas consultants, digital service providers, or platform operators should ensure that tax payment records are properly maintained and aligned with contractual terms. Failure to do so may result in denied input VAT deductions, directly increasing tax costs.

Application of the 0% VAT Rate for Exported Goods and Services

The application of the 0% VAT rate continues to be a key feature of Vietnam’s VAT system for exports. However, Decree 181 and Circular 69 reiterate that the 0% rate is strictly conditional upon sufficient supporting documentation.

Such documentation typically includes:

• Export contracts;
• International transportation documents;
• Customs declarations; and
• Payment records in accordance with foreign exchange regulations.

The reaffirmation of these requirements highlights ongoing audit risks in this area. Enterprises should view the 0% rate not as an automatic entitlement, but as a preferential treatment contingent upon strict compliance with evidentiary standards.

Clarification of Transactions Not Subject to VAT: Capital Transfers

The new regulations provide clearer guidance on capital transfer transactions, confirming that these transactions are not subject to VAT. Importantly, the scope of non-taxable capital transfers explicitly excludes:

• Transfers of investment projects; and
• Sales of assets.

This distinction addresses practical uncertainties that previously arose in restructuring transactions. While the transfer of ownership interests remains outside the scope of VAT, the sale of underlying assets or entire projects may still trigger VAT obligations, depending on their nature.

Enterprises involved in mergers, acquisitions, or internal restructuring should carefully assess transaction structures to determine VAT exposure and avoid unintended tax consequences.

Tightening of Input VAT Deduction Principles

Reduction of Cash Payment Threshold

A significant compliance-oriented change under Decree 181 is the reduction of the cash payment threshold for input VAT deduction from prior levels to VND 5 million (including VAT).

This means that for invoices with a value exceeding VND 5 million, non-cash payment methods are mandatory for VAT deductibility. The threshold reduction reflects the Government’s broader push towards cashless transactions and improved traceability.

Compliance with Non-Cash Payment Regulations

Non-cash payments must comply with Decree 52/2024, which governs acceptable electronic and banking payment methods. Enterprises should ensure that internal payment processes, including corporate banking arrangements and expense reimbursements, align with these requirements.

Failure to comply may result in denied VAT deductions even where invoices are otherwise valid.

Conditions for VAT Refunds Linked to Invoice Compliance

Another notable provision requires that sellers declare and pay VAT on invoices already issued where the buyer subsequently applies for a VAT refund. This rule aims to ensure consistency between output VAT declarations and refund claims across the supply chain.

From a practical perspective, this places additional emphasis on coordination between buyers and sellers, particularly in export transactions and long-term supply arrangements. Enterprises should review contractual terms to manage timing risks related to invoice issuance and VAT declarations.

Practical Implications for Enterprises in Vietnam

The combined effect of Decree 181 and Circular 69 is a more detailed, structured, and compliance-driven VAT framework. While the regulations do not fundamentally alter Vietnam’s VAT system, they significantly reduce grey areas that previously gave rise to inconsistent application and disputes.

For domestic enterprises, the key priorities include:

• Reassessing VAT calculation methods and applicable rates;
• Reviewing refund eligibility and documentation readiness; and
• Updating payment procedures to meet stricter deduction conditions.

For foreign-invested enterprises, particular attention should be paid to:

• Cross-border service arrangements and tax paid on behalf of foreign suppliers;
• Export documentation supporting 0% VAT treatment; and
• Transaction structuring for capital transfers and reorganisations.

Recommended Actions

In light of these changes, enterprises are advised to:

• Conduct an internal VAT compliance review covering invoicing, payment methods, and refund procedures;
• Update accounting and ERP systems to reflect new thresholds and classification rules;
• Train finance and tax teams on revised VAT refund and deduction requirements; and
• Seek professional advice when dealing with complex transactions involving exports or foreign counterparties.

Conclusion

Decree 181/2025/NĐ-CP and Circular 69/2025/TT-BTC represent a coordinated effort to modernise and strengthen Vietnam’s VAT administration from 1 July 2025. By clarifying calculation methods, tightening deduction and refund conditions, and reinforcing documentation standards, the regulations aim to balance taxpayer support with effective tax risk management.

Enterprises that proactively adapt to these changes will be better positioned to manage compliance risks, optimise cash flow, and maintain operational continuity in Vietnam’s evolving tax landscape.

Effective from 1 October 2025

The declaration of Corporate Income Tax (“CIT”) Law No. 67/2025/QH15, effective from 1 October 2025, marks an important step in Vietnam’s ongoing efforts to refine its corporate tax framework in line with evolving business practices and international standards. Rather than introducing a radical overhaul, the new Law focuses on recalibrating the tax base, improving clarity in the treatment of income and expenses, and introducing a more differentiated corporate tax rate structure that better reflects enterprise size and capacity.

These changes arrive at a time when Vietnamese enterprises, both domestic and foreign-invested, are increasingly engaged in corporate restructuring, cross-border transactions, and technology-driven business models. Against this backdrop, the Law seeks to close interpretative gaps, reduce disputes, and strengthen the neutrality and transparency of corporate income taxation.

Expansion and Clarification of Taxable Income

A central theme of Law 67 is the broader and more explicit definition of taxable income, particularly in areas where economic value is created without immediate cash inflows.

Asset Revaluation in Corporate Transactions

Under the new Law, differences arising from asset revaluation are expressly treated as taxable income in a wider range of corporate transactions. These include capital contributions using assets, asset transfers in mergers, consolidations or divisions, changes in ownership structure, and changes in business type.

In previous practice, asset revaluation gains arising from internal reorganisations were often subject to inconsistent tax treatment, particularly where transactions were driven by restructuring objectives rather than outright sales. Law 67 clarifies that where asset values are re-determined and ownership or economic control changes, any resulting increase in value constitutes taxable income for CIT purposes.

This change reflects a broader policy trend towards substance-over-form taxation, ensuring that economic gains are taxed regardless of whether they are realised through cash transactions. For enterprises planning mergers, internal restructurings, or business conversions, this amendment underscores the importance of conducting tax impact assessments early in the transaction planning process.

Contractual Grants, Bonuses, and Penalties

Law 67 also explicitly brings contractual grants, bonuses, and penalties within the scope of taxable income. Such items are commonly encountered in commercial contracts, particularly in construction, infrastructure development, energy projects, and long-term service arrangements.

By clarifying the tax treatment of these contractual amounts, the Law reduces uncertainty in determining whether such income should be classified as operating income or incidental gains. From a compliance perspective, enterprises should ensure that all contractual receipts, regardless of their accounting classification, are reviewed for CIT implications.

Deductible Expenses: Greater Alignment with Business Reality

While expanding taxable income, Law 67 simultaneously introduces more pragmatic rules on deductible expenses, acknowledging that commercial operations do not always conform neatly to annual accounting periods.

Expenses Not Directly Linked to Current Revenue

The Law allows the deduction of certain expenses incurred for business operations even where they do not directly correspond to revenue generated during the same tax period, provided such expenses comply with regulatory requirements.

This provision is particularly relevant for enterprises engaged in long-term projects, research and development, or capacity-building activities, where expenses are incurred well in advance of revenue generation. By recognising these realities, the Law reduces pressure on enterprises to artificially align expenses with revenue and helps prevent distortions in taxable income calculations.

Nevertheless, deductibility remains contingent on the expenses being genuine, properly documented, and incurred for business purposes. Tax authorities are likely to continue scrutinising such expenses closely, making documentation and internal controls critical.

Treatment of Non-Refundable Input VAT

Another notable clarification concerns input VAT that cannot be fully deducted and does not qualify for a VAT refund. Under Law 67, such VAT amounts may be treated as deductible expenses for CIT purposes.

This adjustment helps mitigate the cost impact of irrecoverable VAT, particularly for enterprises engaged in partially exempt activities or mixed VAT treatments. From a policy perspective, it promotes tax neutrality by ensuring that VAT which cannot be recovered does not inflate the effective corporate tax burden.

Introduction of a Tiered Corporate Income Tax Rate Structure

Perhaps the most visible change under Law 67 is the introduction of a more graduated CIT rate regime, reflecting enterprise size and revenue capacity.

Revised CIT Rates

Category of Enterprise	Annual Revenue	CIT Rate
Micro enterprises	≤ VND 3 billion	15%
Small enterprises	> VND 3 billion – ≤ VND 50 billion	17%
General enterprises	> VND 50 billion	20%

While the standard 20% rate remains unchanged for larger enterprises, the reduced rates for micro and small enterprises represent a meaningful policy shift. These rates are designed to support business sustainability, encourage formalisation, and improve cash flow for smaller operators.

From a compliance standpoint, revenue thresholds take on increased significance. Enterprises must ensure accurate revenue recognition and monitoring, as misclassification could lead to reassessments and penalties. For growing enterprises approaching threshold limits, forward-looking tax planning will be increasingly important.

Adjustment of Tax Incentives for New Technology Products

Law 67 also revises tax incentives applicable to income derived from the sale of new technology products. Specifically, the preferential CIT exemption period is reduced from five years to a maximum of three years.

This adjustment reflects a recalibration of incentive effectiveness, ensuring that tax benefits remain targeted and time-bound. While the shortened incentive period may affect long-term profitability projections for technology-focused enterprises, it also encourages businesses to prioritise efficiency and scalability rather than long-term reliance on tax exemptions.

Enterprises operating in innovation-driven sectors should reassess existing incentive assumptions and consider alternative support mechanisms available under other investment or innovation policies.

Implications for Corporate Restructuring and Investment Decisions

Taken together, the amendments under Law 67 have significant implications for corporate restructuring, investment planning, and financial modelling.

• Asset revaluation gains arising from restructuring are now more clearly taxable, increasing the importance of valuation methodologies.
• Contractual income streams must be reviewed comprehensively to ensure correct tax treatment.
• Reduced CIT rates offer tangible benefits to SMEs but require careful revenue management.
• Technology-related incentives remain available but on a more limited timeline.

These changes highlight the need for enterprises to integrate tax considerations into broader strategic decision-making rather than treating tax compliance as a purely administrative function.

Considerations for Foreign-Invested Enterprises

For foreign-invested enterprises (“FIEs”), Law 67 reinforces Vietnam’s commitment to aligning tax outcomes with economic substance. Internal restructurings, changes in ownership, or conversions of legal form may now give rise to taxable revaluation gains more clearly than before.

Foreign groups should also consider how Vietnam’s revised CIT rules interact with overseas tax regimes, particularly in relation to valuation, profit recognition, and potential double taxation. Advance planning and coordination across jurisdictions will be key to managing these risks.

Conclusion

Corporate Income Tax Law No. 67/2025/QH15 represents a measured but impactful evolution of Vietnam’s corporate tax regime. By expanding the taxable income base, refining deductible expense rules, introducing differentiated tax rates, and recalibrating incentives, the Law seeks to balance fiscal integrity with business support.

Enterprises operating in Vietnam should proactively review their tax positions ahead of the Law’s effective date to ensure compliance, manage risk, and identify opportunities arising from the new framework. Early preparation will be critical as tax authorities continue to enhance enforcement and analytical capabilities in the coming years.

Effective Date: from 1 July 2025

Decree No. 69/2024/ND-CP, effective from 1 July 2025, marks an important milestone in Vietnam’s digital governance framework by formally requiring enterprises and organizations to transition to electronic identification (e-ID) accounts issued by the Ministry of Public Security for the purpose of carrying out administrative and tax procedures. This change reflects the Government’s broader push toward digital transformation, data integration, and enhanced transparency across state management systems.

Under Clause 4, Article 40 of Decree 69, all user accounts previously created on the National Public Service Portal and on ministerial and provincial administrative procedure information systems will expire as of 30 June 2025. From 1 July 2025 onward, these legacy accounts will no longer be valid for accessing online public services. As a result, enterprises will be required to use VNeID-based electronic identification accounts to continue performing essential administrative functions, including electronic tax declarations and other regulatory filings.

Overview of Electronic Identification Account Registration

An electronic identification account functions as a digital “identity card” for enterprises and organizations within Vietnam’s national electronic identification and authentication system. Similar in concept to a citizen’s personal identity card, the enterprise e-ID enables competent authorities to accurately identify, manage, and supervise business entities across different administrative platforms.

By integrating enterprise information into a centralized electronic system, the e-ID framework enhances data consistency, security, and transparency. It also supports the Government’s ability to monitor compliance more effectively, reduce administrative fragmentation, and design more targeted and data-driven public policies, including tax policies applicable to enterprises operating in Vietnam.

Electronic identification is therefore not merely a technical requirement, but a foundational component of Vietnam’s evolving digital infrastructure for public administration and corporate regulation.

Key Enterprise Information Integrated into the e-ID System

According to Article 6 of Decree 69/2024/ND-CP, the electronic identification account of an enterprise contains a standardized set of core information, including:

• Enterprise identification number
• Enterprise name
• Date of establishment
• Head office address
• Enterprise registration number
• Tax code
• Electronic identification code

Once integrated, the e-ID account serves as the single verified reference point for the enterprise when interacting with state authorities through electronic channels.

Permanent Data Storage and Access History

Decree 69 also introduces clear rules on data storage and traceability. Under Article 17, all information related to electronic identification, along with any integrated data, will be permanently stored in the national electronic identification and authentication system.

In addition, the system records the access history of each electronic identification account. Such access logs must be retained for a minimum period of five years from the date of access. Enterprises and organizations have the right to review and retrieve information related to their own access history, which supports accountability and internal compliance monitoring.

At the same time, the managing authority of the electronic identification system is permitted to use this data for lawful state management purposes. Any other use of the information must strictly comply with applicable legal regulations, reinforcing safeguards around data protection and lawful processing.

Conditions for Enterprise e-ID Registration

Decree 69 allows enterprises and organizations to be granted an electronic identification account regardless of level. However, a critical prerequisite applies to the registration process: the legal representative of the enterprise must possess a Level-2 personal VNeID account in order to successfully register the enterprise’s e-ID.

This requirement underscores the importance of aligning personal identification data with enterprise registration data. The legal representative’s information must match records in the national population database, as inconsistencies may delay or prevent successful registration.

Where registration is conducted through an authorized representative, an appropriate authorization letter must be prepared in accordance with relevant regulations.

Practical Implications for Enterprises

From a practical perspective, the expiration of legacy public service portal accounts on 30 June 2025 creates a hard operational deadline. Enterprises that fail to complete the transition to an electronic identification account in time may encounter significant disruptions to their administrative and tax compliance activities.

Without a valid e-ID account, enterprises may be unable to submit applications for administrative procedures, carry out electronic tax filings, or access essential public services provided through government platforms. This could lead to delays in compliance, interruptions to routine operations, and increased administrative burden at a time when digital procedures are becoming the default.

While Decree 69 does not currently impose explicit penalties for failing to register an electronic identification account, the practical consequences of non-registration function as a de facto enforcement mechanism. In effect, the inability to access digital public services may hinder business continuity and operational efficiency.

Benefits of Early Registration

Registering an electronic identification account offers several tangible benefits for enterprises and organizations. By consolidating enterprise data into a single verified digital identity, businesses can significantly reduce the time and cost associated with repetitive administrative procedures.

The integration of information allows for faster access to online public services, improved responsiveness to regulatory requirements, and more streamlined interactions with tax authorities and other government agencies. Over time, this centralized digital identity is expected to support smoother compliance processes and reduce administrative friction.

From a governance perspective, electronic identification also enhances transparency and contributes to anti-corruption efforts by minimizing manual interventions and improving traceability within administrative systems.

Electronic Identification Account Registration Methods]

Criteria	Option A: Online Registration via VNeID App	Option B: In-Person Registration at Local Police Authority
Registration channel	Mobile application (VNeID – Android/iOS)	Competent local police authority
Who may apply	Legal representative or authorized individual holding a Level-2 personal VNeID account	Legal representative or authorized individual
Initial requirements	Installation of VNeID app and access to a Level-2 personal VNeID account	Physical presence at the authority and preparation of hard-copy documents
Registration path	“Organizational Identification” → “Register Organizational Identification” within the VNeID app	Submission of Form TK02 – Application for Electronic Identification Account
Organization types selectable	Enterprises; entities with tax codes but no business registration; cooperatives; unregistered or non-coded organizations	Applicable to all organization types supported under Decree 69
Information declaration	Electronic declaration of enterprise details, depending on organization type	Manual declaration supported by documentary evidence
Authentication method	Passcode authentication (with reset function if forgotten)	Verification by competent authority using national and specialized databases
Confirmation requirement	Applicant confirms the accuracy and completeness of declared information before submission	Applicant signs and submits Form TK02
Processing time	Subject to system verification; dependent on database availability	Up to 3 working days if information exists in databases; up to 15 working days if not
Notification of results	Displayed within the VNeID application upon approval	Notification sent via registered phone number or official address
Outcome	Electronic identification code displayed in the VNeID app	Electronic identification code issued after approval
Suitability	Recommended for enterprises seeking faster and more efficient registration	Suitable where online registration is not feasible or information is not digitized

Recommendations

From a compliance and operational standpoint, the period leading up to 1 July 2025 represents a critical transition window for enterprises. Early registration is strongly recommended to avoid system congestion, unexpected data discrepancies, or procedural delays as the deadline approaches.

Enterprises should carefully review the information stated on their Enterprise Registration Certificate and ensure consistency with national databases, particularly regarding the legal representative’s personal details. Any discrepancies should be rectified in advance to facilitate a smooth registration process.

Professional support may be beneficial, especially for foreign-invested enterprises or organizations with complex authorization structures. Timely guidance can help ensure that registration is completed in full compliance with applicable regulations and that enterprises remain fully operational in the post-transition digital environment