Tax and Finance Newsletter – July 2026

ACAC – Tax and Finance Newsletter, July 2026

A Wave of Decrees Implementing the 2025 Tax Administration Law Takes Effect, Together with Updated Beneficial-Owner Regulations

At Anh Consulting and Auditing Co., Ltd. (ACAC), we place strong emphasis on keeping pace with regulatory developments and providing accurate professional knowledge to help businesses make effective financial decisions, remain compliant, and adapt flexibly in a changing policy environment.

July 2026 saw a wave of decrees and circulars implementing the 2025 Tax Administration Law (effective from 1 July 2026) issued in near-simultaneous fashion — covering tax registration, related-party transactions, and administrative penalty levels. Notably, the regulations on an enterprise’s beneficial owner were also updated, affecting the ownership-transparency obligations of most Vietnamese legal entities. ACAC’s July 2026 newsletter summarizes the most notable updates to help enterprises stay informed and adjust accordingly in a timely manner.

Tax Policy Guidance and Updates

Tax Administration and Tax Registration

The Ministry of Finance issued Circular No. 89/2026/TT-BTC guiding the Tax Administration Law and Decree No. 252/2026/ND-CP, effective from 1 July 2026, together with important transitional provisions: tax declaration dossiers for tax periods prior to 1 July 2026 continue to use the previous forms; decisions and notices issued by the tax authority before the Circular’s effective date continue to be implemented in accordance with their original content until they expire; and in most cases, refund and tax exemption/reduction dossiers already received but not yet resolved continue to be processed under the previous procedures. On the same day, the Ministry of Finance also issued Circular No. 90/2026/TT-BTC on tax registration, together with 21 new tax registration forms applicable to specific categories of taxpayer: organizations, business households, individuals, foreign contractors, foreign e-commerce suppliers, diplomatic missions, and others. Enterprises should review these to ensure the correct form is used when carrying out registration procedures or updating tax information.

Corporate Income Tax (CIT) – Related-Party Transactions

On 30 June 2026, the Government issued Decree No. 255/2026/ND-CP on tax administration for related-party transactions, applicable from the 2026 CIT tax period. The Decree specifically prescribes the method for comparing the price of related-party transactions with the price of independent transactions: the price of a product in a related-party transaction must be adjusted to the independent transaction price where there is no material difference in product characteristics and contractual conditions; where a material difference exists, it must be eliminated before the comparison is made. Notably, an enterprise purchasing machinery or equipment from an overseas related party must hold documentation evidencing that the purchase price complies with the arm’s-length principle at the time of purchase — for new equipment, this is compared against the invoice price at which the related party purchased from an independent party, while for used equipment, the value must be re-determined in accordance with the current regulations on fixed-asset depreciation. The result of any related-party transaction price adjustment is used as the basis for calculating tax but may not reduce the tax obligation payable to the state budget.

Personal Income Tax (PIT)

On 30 June 2026, the Ministry of Finance issued Circular No. 87/2026/TT-BTC detailing the dossier required to determine a taxpayer’s child as a dependant, applicable from 1 July 2026. The basic dossier comprises a birth certificate (or, as applicable, an adoption decision/paternity-maternity recognition decision) and the child’s citizen identity card (if already issued); depending on the specific case — a stepchild of the spouse, a child who is disabled or has lost civil act capacity from the age of 18, or a child currently studying at university, college, vocational secondary school, or a vocational training institution — the taxpayer must provide corresponding supporting documents (marriage certificate, disability confirmation, student card, or school confirmation).

Other Taxes

On 22 July 2026, the Government issued Decree No. 292/2026/ND-CP guiding the Law on Foreign Trade Management, effective from 5 September 2026, on the right to freedom of import/export business: a Vietnamese trader without foreign investment capital may conduct import/export business irrespective of its registered business lines, except for goods on the list of prohibited or temporarily suspended imports/exports; a foreign-invested enterprise may directly export, or export through an entrustment arrangement, products it has manufactured, and may import machinery and raw materials in service of the objectives of its registered investment project; a foreign trader without a commercial presence in Vietnam may only operate within the scope of import/export rights prescribed under current regulations. On land matters, Decree No. 281/2026/ND-CP (effective from 31 August 2026) adds a principle for administrative penalty purposes: a husband and wife jointly named on a land use right are penalized as a single individual, rather than having the penalty doubled based on the number of persons named.

Updated Beneficial-Owner Regulations and Increased Tax Violation Penalties

On 23 July 2026, the Government issued Decree No. 296/2026/ND-CP amending the regulations on an enterprise’s beneficial owner. Under the amendment, a beneficial owner is, in the first instance, an individual who directly or indirectly owns 25% or more of the charter capital, or 25% or more of the voting shares; a group of individuals related by family or by contract who together reach this threshold is likewise determined to be a beneficial owner. For a partnership, all general partners are beneficial owners, regardless of their respective capital contribution ratios. Where no individual satisfies the ownership criteria above, the enterprise determines its beneficial owner based on actual control rights (the right to appoint/remove management, decide financial policy, or reorganize or dissolve the enterprise); if a beneficial owner still cannot be determined, the enterprise records the manager holding the greatest authority as the beneficial owner. Enterprises should review and update their beneficial-owner information in accordance with these new regulations. On penalties, on 21 July 2026 the Government issued Decree No. 291/2026/ND-CP adding penalty levels for violations relating to the provision of information for international tax information exchange, ranging from VND 10 million to VND 100 million depending on the severity of the violation (late provision, inaccurate provision, or failure to provide/collusion to conceal information).

Other Matters

The Government issued Decree No. 283/2026/ND-CP (effective from 10 September 2026) prescribing penalty levels for late payment of compulsory social insurance: the penalty is calculated based on the number of employees affected by the violation, ranging from VND 5 million (fewer than 10 employees) to VND 75 million (1,000 employees or more); the act of late social insurance payment specifically is subject to a fine of 12–15% of the total overdue amount as at the time the record of violation is made, capped at VND 75 million. Enterprises with a large workforce should pay particular attention to complying with social insurance payment deadlines in order to avoid this significant penalty.

Transparency – Updates – Partnership

Through its monthly newsletter, ACAC aims not only to deliver authoritative information but also to help enterprises understand the practical impact of policy changes, enabling them to proactively adjust their financial strategies and risk management.

We believe that transparency, professional rigor, and timely updates form the foundation for the sustainable growth of Vietnam’s business community in this era of global integration.

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