Executive Summary
Effective from 1 July 2026, Circular No. 90/2026/TT-BTC expands Vietnam’s tax registration framework by adding three new groups subject to direct registration with tax authorities, with particular relevance to digital business models, cross-border activities and Global Minimum Tax compliance.
01. Background and Regulatory Context
The Ministry of Finance issued Circular No. 90/2026/TT-BTC to provide guidance on tax registration and replace Circular No. 86/2024/TT-BTC.
The Circular implements the Law on Tax Administration No. 108/2025/QH15 and Decree No. 252/2026/ND-CP, while expanding the scope of taxpayers required to register directly with tax authorities.
The changes are particularly relevant to businesses operating through digital platforms, cross-border business models and entities subject to the Global Minimum Tax.
02. Three New Groups Subject to Tax Registration
Under Clause 2, Article 4 of Circular No. 90/2026/TT-BTC, taxpayers required to register directly with tax authorities include a broad range of organizations and individuals. Compared with Circular No. 86/2024/TT-BTC, three new groups are specifically added:
01
Non-resident individuals conducting business through e-commerce platformsNon-resident individuals conducting business through e-commerce platforms that do not provide online ordering and payment functions are now subject to direct tax registration.
02
Domestic e-commerce and digital platform operatorsDomestic platforms with online ordering and payment functions must register for tax where they are responsible for withholding and paying tax on behalf of foreign suppliers, business households and individuals.
03
Entities subject to top-up Corporate Income TaxOrganizations required to declare and pay top-up Corporate Income Tax under the Global Minimum Tax rules are also included among the new groups subject to direct tax registration.
03. Other Taxpayers Covered by the Framework
Organizations outside business registrationOrganizations and businesses not required to register through the business registration authority.
Foreign contractors and suppliersForeign contractors and foreign suppliers with tax obligations in Vietnam.
Withholding entitiesOrganizations and individuals responsible for withholding and paying tax on behalf of other taxpayers.
Households and individualsHouseholds and individuals conducting business activities or receiving taxable personal income.
PIT dependentsDependents registered for personal income tax purposes.
Special-sector taxpayersOrganizations involved in oil and gas activities, tax collection agents and other entities with obligations to the State Budget.
Overall direction: The expanded scope supports a more comprehensive taxpayer database covering both traditional and digital business models.
04. What the New Rules Mean for Taxpayers
Organizations and individuals should review their business activities and tax obligations to determine whether they fall within the newly regulated groups. Failure to complete tax registration within the prescribed timeframe, or failure to follow required procedures, may lead to administrative sanctions under applicable tax administration regulations.
E-commerce activities
Review whether the business model involves online transactions and whether the platform provides ordering and payment functions.
Tax withholding obligations
Platform operators should determine whether they are responsible for withholding, declaring and paying tax on behalf of suppliers or individuals.
Cross-border transactions
Foreign suppliers and non-resident individuals should review whether their activities in Vietnam trigger direct tax registration obligations.
Global Minimum Tax
Organizations subject to top-up Corporate Income Tax should assess their registration and reporting requirements under the new framework.
05. Supporting Digital Transformation in Tax Administration
The new rules reflect Vietnam’s efforts to modernize tax administration in response to the rapid development of the digital economy.
By bringing additional digital-platform participants and Global Minimum Tax taxpayers into the tax registration framework, tax authorities can build a more complete taxpayer database, strengthen data collection and improve risk-based tax administration.
Requiring certain platforms to withhold and remit tax at source may also improve compliance while reducing the administrative burden on individual businesses and taxpayers.
06. Key Takeaway for Businesses
Circular No. 90/2026/TT-BTC marks an important update to Vietnam’s tax registration framework. The addition of non-resident e-commerce individuals, domestic digital platform operators with tax withholding obligations and Global Minimum Tax top-up taxpayers signals a broader approach to tax administration in the digital economy.
Businesses should proactively review their current activities, tax registration status and internal compliance procedures to determine whether the new requirements apply.
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