Vietnam Passes New Tax Administration Law

On December 10, 2025, the National Assembly of Vietnam passed the Tax Administration Law No. 108/2025/QH15. This law will replace the Tax Administration Law No. 38/2019/QH14 promulgated on June 13, 2019, and the provisions amended and supplemented by Law No. 56/2024/QH15.

Most provisions of the new law will take effect on July 1, 2026. Articles 13 and 26, concerning the declaration, settlement, tax deduction, and use of electronic invoices for businesses and individual merchants, have already taken effect on January 1, 2026.

Main revisions include:

(1) Expanding the scope of taxpayers. Taxpayers include foreign organizations and individuals engaged in business activities or deriving income in Vietnam, as well as foreign organizations and individuals conducting business on e-commerce platforms and other digital platforms;

(2) Strengthening tax administration for e-commerce and digital platforms. E-commerce and digital platform operators are required to collect and pay taxes on behalf of overseas platform merchants. Merchants must independently calculate their income from the production and operation of tax-exempt or non-taxable goods and services in accordance with the regulations on value-added tax and individual income tax, and truthfully declare their annual income to the tax authorities;

(3) Shortening the period for correcting errors in tax returns. The period for taxpayers to correct errors or omissions in their submitted tax return materials after the tax return deadline is shortened from 10 years to 5 years;

(4) Clarifying transitional arrangements. Tax arrears that are not paid by June 30, 2026, will be handled in accordance with the new law; tax exemptions or reductions incurred before July 1, 2026, will continue to be handled in accordance with the old law; tax inspections that have been initiated before July 1, 2026, but for which no conclusion or decision has yet been issued, will continue to be carried out in accordance with the old law.