Decree No. 310/2025/ND-CP was promulgated by the Government on 2 December 2025, amending and supplementing several articles of Decree No. 125/2020/ND-CP on administrative penalties for tax and invoice-related violations. The Decree takes effect from 16 January 2026.

Expanded definition and additional subjects

• Administrative violations now include violations of tax administration laws, tax laws and other state budget revenues managed and collected by tax authorities, including land use fees, land rentals and revenues under the laws on management and investment of state capital in enterprises.
• Additional subjects include organizations and individuals authorized to perform tax obligations, organizations and individuals registering, declaring and paying taxes on behalf of taxpayers, and constituent units under the Global Anti-Base Erosion rules.

Force majeure and principles for multiple violations

The Decree supplements regulations on force majeure events, including natural disasters, catastrophes, epidemics, fires, unexpected accidents, wars, riots, strikes or other objectively unforeseeable events where the taxpayer is unable to remedy the consequences despite taking all necessary measures within its capability.

Large-scale violations and penalty levels

• Tax evasion is considered large-scale from VND 100 million or more.
• Invoice-related violations are considered large-scale from 10 invoices or more.
• Organizations and individuals responsible for providing information to tax authorities may face increased penalty levels for late, inaccurate or concealed information.

Other notable changes

• Tax officials performing official duties may impose monetary fines of up to VND 20,000,000 for tax procedures and VND 10,000,000 for invoice violations.
• Sanctioning authority for invoice-related violations is expanded to include tax officials, heads of local tax offices, directors of district tax departments and chairpersons of commune-level People’s Committees.
• Incorrect declarations may be exempt from penalties if the taxpayer voluntarily submits an amended declaration and fully pays tax before the tax authority announces an inspection or audit decision.

Decree No. 293/2025/ND-CP prescribes the monthly and hourly minimum wages applicable to employees working under labor contracts. The Decree takes effect from 1 January 2026 and replaces Decree No. 74/2024/ND-CP.

Employers operating in industrial parks, export processing zones, high-tech zones or concentrated digital technology zones located across areas with different minimum wage levels must apply the highest applicable minimum wage level.

The Tax Department received Official Letter No. 3374/CCTKV02-NVDTPC dated 30 June 2025 from the Regional Tax Sub-Department II regarding templates and forms for implementing Resolution No. 98/2023/QH15.

Guidance on CIT declaration

• A five-year CIT exemption is granted for income generated from innovative start-up activities arising within Ho Chi Minh City.
• PIT and CIT are exempted for income from the transfer of contributed capital or the right to contribute capital to innovative start-ups within the city.
• Income exempted under Resolution No. 98/2023/QH15 is a special case and is not yet included in the selectable list on the tax declaration application.

The Tax Department will update the category “Income exempted under Resolution No. 98/2023/QH15 dated June 24, 2023” to facilitate correct declaration by taxpayers.

Guidance on PIT declaration

Individuals earning income from capital transfers shall declare tax using forms issued together with Circular No. 80/2021/TT-BTC and Decree No. 126/2020/ND-CP. The Tax Department acknowledges the current limitation and will add items related to tax-exempt income under Resolution No. 98/2023/QH15 when drafting the Circular guiding the amended Law on Tax Administration.

The Dong Nai Provincial Tax Department received Official Letter No. 2025/CVKEV dated 19 June 2025 from Kawamura Electric Vietnam Co., Ltd. regarding PIT declaration for foreign experts.

Tax residency and taxable income

Under Decree No. 65/2013/ND-CP, resident individuals are taxed on income arising both within and outside Vietnam, regardless of where the income is paid. Non-resident individuals are taxed on income arising in Vietnam, regardless of where the income is paid. A resident individual is a person present in Vietnam for 183 days or more in a calendar year or 12 consecutive months, or a person with permanent residence in Vietnam.

PIT finalization

Where a resident individual earns employment income from two or more sources, including income subject to direct declaration and income from which tax has been withheld by the paying organization, the individual must directly file PIT finalization with the tax authority by the PIT finalization deadline.

The Tax Department received Official Letter No. 5581/BNI-QLDN1 dated 14 October 2025 from the Bac Ninh Tax Department and Official Letter No. 2249/KHH-NVDTPC dated 31 October 2025 from the Khanh Hoa Tax Department regarding VAT policies.

Deferred or installment payment transactions

For deferred or installment payment of goods and services valued at VND 5 million or more, if at the payment due date under the contract or its annex the business does not have non-cash payment documents, the business must declare and adjust to reduce the deductible input VAT for the value of goods or services without such documents in the tax period when the payment obligation arises.