Published on 18. February 2026
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Key Highlights of Vietnam´s Law on Tax Administration 2025

  • From News from ASEAN - Q1 2026
  • Highlights on Vietnam´s Tax Administration Law
  • Enhanced international tax management framework
  • Introduction of automated tax refund, exemption and reduction mechanisms
Michael Wekezer
Partner
Attorney at Law (Germany)
Law No. 108/2025/QH15 on Tax Administration was approved by the Office of the National Assembly of Vietnam at the 10th session of the 15th National Assembly on 10 December 2025 and will become effective as of 1 July 2026.

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The Law introduces several notable changes, including:

Addition to the categories of individuals required to fulfill tax obligations prior to exiting Vietnam

The scope of individuals required to fulfill outstanding tax obligations before exiting Vietnam may extend beyond legal representatives to include certain categories of beneficial owners.

Time limit for tax dossier supplementation

The time limit for tax dossier supplementation is 5 years, together with strengthened post-audit and post-inspection management.

Expansion of prohibited activities in tax administration

The Law supplements prohibited acts in tax administration, including:

  • Abuse of position or authority to unlawfully disclose or leak taxpayer information or to falsify inspection results;
  • Obstruction, delay or failure to provide information and documents for tax inspections and supervision;
  • Illegal creation or use of electronic invoices and documents;
  • Unauthorized access to, misuse of or damage to taxpayer information systems and dissemination of false information affecting tax authorities or taxpayers.

Enhanced international tax management framework

The amended Law officially incorporates the implementation of the Global Minimum Tax regulations into the tax authority’s international tax administration mandate. In addition, mechanisms such as the Mutual Agreement Procedure (MAP) and Advance Pricing Agreements (APA) are comprehensively stipulated to facilitate dispute resolution and prevent double taxation.

Introduction of automated tax refund, exemption and reduction mechanisms

The Tax Authority implements automated tax refund, tax exemption and tax reduction processes based on data systems, risk management criteria, automated processing workflows and information security safeguards. The Tax Authority is responsible for rolling out automated tax refund, exemption and reduction mechanisms in phases, in line with practical conditions as well as the availability of infrastructure and information technology applications.

 

 

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