On June 30, 2026, the Government officially issued Decree 252/2026/ND-CP (“Decree 252”) detailing a number of articles and measures for implementation and guidance on the Law on Tax Administration No. 108/2025/QH15. Accordingly, Decree 252 replaces and supplements many contents of Decree 126/2020/ND-CP (“Decree 126”), thereby improving management mechanisms, optimizing declaration procedures, and creating a more favorable legal framework for individuals and businesses. Details are as follows:
I. Clarifying the mechanism for publicly disclosing tax violators on electronic information portals
1. Taxpayers who do not explain invoice risks according to system warnings will have their information publicly disclosed on electronic information portals
Compared to the previous provisions in Clause 1, Article 29 of Decree 126, the new provisions in Article 4 of Decree 252 have adjusted the regulations on cases of public disclosure of taxpayer information. In particular, it supplements the behavior of failing to fulfill the tax authority's request to explain invoice risks based on warnings from the tax authority's e-invoice application system. This is a mandatory case of public disclosure on the electronic information portals of tax management authorities at all levels.
For other violations, based on actual conditions, the head of the tax management authority directly managing the taxpayer or the tax management authority managing the state budget revenue sources shall decide to apply one or several additional forms, such as: public disclosure on mass media; posting at the headquarters of the tax management authority; through public receptions, press conferences, press releases, activities of spokespersons of tax management authorities at all levels in accordance with the law, and other public disclosure forms in accordance with relevant regulations...
2. Overdue tax payment of 90 days results in automatic monthly periodic public disclosure
This is an entirely new provision under Point c, Clause 3, Article 4 of Decree 252. In addition to supplementing regulations on the content and forms of public disclosure, the Decree also adds provisions for cases where more than 90 days have elapsed from the deadline for paying taxes and other state revenues, late payment interest, fines, or from the expiration of the deadline for executing administrative decisions on tax administration without voluntary compliance by the taxpayer or guarantor. Accordingly, the Tax Management Information System will automatically publicly disclose information on the electronic information portals of tax management authorities at all levels on a monthly periodic basis.
3. Supplementing mechanisms for terminating and updating public disclosure of information
Clause 4, Article 4 of Decree 252 supplements specific regulations on mechanisms to terminate and update publicly disclosed information. Accordingly, when taxpayers have completed their tax obligations, the Tax Management Information System automatically updates the status of the taxpayer to completed obligations.
For cases where taxpayer information is publicly disclosed due to being more than 90 days overdue from the deadline for paying taxes, other state revenues, late payment interest, fines, or from the expiration of the deadline for executing administrative decisions on tax administration without voluntary compliance, at the time of publicly disclosing information for the new period, the previously disclosed information will simultaneously cease to be displayed. In cases where taxpayers complete their tax obligations before the public disclosure is terminated, based on updates from the Tax Management Information System, the electronic information portals of tax management authorities at all levels will automatically display supplementary information regarding the taxpayer's completion of tax obligations.
This regulation ensures the legitimate rights, interests, and reputation of taxpayers after rectifying violations, while ensuring that public information on the tax authority's electronic portal always reflects actual conditions, limiting the maintenance of obsolete or misleading information for searching organizations and individuals.
4. Supplementing regulations on confidential taxpayer information
According to Point a, Clause 2, Article 4 of Decree 252, in cases where a taxpayer does not operate at the registered address, based on tax management data and information provided by competent state agencies, the tax authority is permitted to publicly disclose information about sole proprietors, owners of single-member limited liability companies, general partners, legal representatives of enterprises, individual businesses, and household business owners. The tax authority may only publicly disclose the full name and the last 04 digits of the personal identification number (citizen ID card or passport number); all remaining characters must be masked or encrypted.
This adjustment not only minimizes the risk of leaking sensitive data of business owners but also ensures the principles of publicity and transparency in the process of handling administrative tax violations.
II. Supplementing tax registration deadlines for branches and transaction offices of credit institutions
Point a.1, Clause 3, Article 6 of Decree 252 stipulates that the deadline for initial tax registration of branches and transaction offices of credit institutions is 10 working days from the opening date. This is content that Decree 126 previously did not specify, causing confusion for many credit institutions when determining the registration timeline.
III. Supplementing regulations on taxpayers' responsibilities in certain cases
1. Taxpayers changing personal information do not need to perform procedures with tax authorities
According to current regulations, when there are changes to tax registration information, taxpayers must still perform procedures to notify the tax authority of changes as prescribed.
However, Point e.3, Clause 3, Article 6 of Decree 252 has added a provision that in cases where the National Population Database has been connected and automatically synchronized with the tax industry database, taxpayers changing information regarding full name, personal identification number, date of birth, or passport do not need to perform procedures to change information with the tax authority, as the Tax Management Information System will automatically send an update notification to the taxpayer.
This regulation contributes to simplifying administrative procedures, reducing time and compliance costs for taxpayers when data between state agencies is connected and operated in sync.
2. Supplementing taxpayers' responsibilities in cases of receiving notice of non-operation at the registered address
Point e, Clause 1, Article 7 of Decree 254 stipulates that in cases where taxpayers are notified by the tax authority as not operating at the registered address, taxpayers have the responsibility to:
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Be held responsible for tax obligations during the time notified by the tax authority as not operating at the registered address, including registered addresses of dependent units and business locations, and comply with notices and decisions of tax management authorities and competent state agencies in accordance with the law;
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Not perform procedures for temporary suspension of operations/business when the tax authority has issued a notice that the taxpayer is not operating at the registered address, and may only perform procedures for temporary suspension of operations/business after completing procedures to restore the tax identification number.
Disallowing taxpayers from performing temporary suspension procedures before restoring their tax identification numbers contributes to preventing the exploitation of changes in a company's legal status to evade tax obligations or prolong the processing of violations.
IV. Abolishing regulations on total duration of temporary suspension of operations/business for organizational taxpayers
Previously, under Point c, Clause 1, Article 4 of Decree 126, organizational taxpayers were subject to a total temporary suspension period of no more than 2 years for 2 consecutive registrations. However, under Decree 252, this regulation has been abolished, thereby removing the cap on the maximum allowable temporary suspension period and increasing flexibility for businesses to proactively build plans for temporary suspension suitable to their actual needs.
V. Shortening the time for canceling temporary exit suspensions
Point c, Clause 5, Article 28 of Decree 252 stipulates that as soon as a taxpayer meets the conditions for canceling a temporary exit suspension, the tax authority will issue a notification canceling the temporary exit suspension on the tax management information system to send to the immigration management authority. Based on the tax authority's notice, the immigration management authority will perform the cancellation of the temporary exit suspension in accordance with regulations. Previously, the tax authority issued the notification canceling the temporary exit suspension within 24 working hours from when the taxpayer completed their tax obligations.
In addition to shortening processing time, the Decree supplements mechanisms to safeguard taxpayers' rights under Point b, Clause 5, Article 28 of Decree 252. Accordingly, in cases where payment has been made but information has not yet been updated on the tax management information system, taxpayers can submit feedback along with a copy of the payment receipt electronically through the tax management information system. After receipt, the tax authority will inspect, compare, update data, and issue a notification canceling the temporary exit suspension if the taxpayer has fully met all prescribed conditions.
This regulation enables taxpayers to proactively resolve cases of delayed tax payment data updates, limiting impacts on exit travel due to latency in data synchronization across systems.
VI. Supplementing settlement deadlines for individuals present in Vietnam for less than 183 days in 01 calendar year
Point c, Clause 5, Article 10 of Decree 252 adds a provision: In cases where within 01 calendar year, an individual is present in Vietnam for less than 183 days, but calculated over 12 consecutive months from the first day of presence in Vietnam is present for 183 days or more, the deadline for submitting personal income tax finalization dossiers for the first year is no later than the last day of the 4th month starting from the last day of the month completing 12 consecutive months.
The addition of this provision helps clearly determine the deadline for submitting personal income tax finalization dossiers for the first year's tax period, creating a basis for taxpayers to proactively fulfill tax obligations and reducing obstacles in determining dossier submission deadlines.
VII. Supplementing 06 cases exempt from submitting tax declaration dossiers and other revenue collections
Compared to previous regulations in Clause 3, Article 7 of Decree 126 (as amended by Decree 91/2022/ND-CP), the new provision in Article 11 of Decree 252 continues to inherit current cases exempt from submitting tax declaration dossiers and adds 6 new cases, including:
Case 1: Vietnamese entities and individuals withholding and paying value-added tax and corporate income tax on behalf of foreign contractors in accordance with tax laws and carrying out monthly tax declarations, where no tax withholding arises during that month.
Case 2: Taxpayers eligible for tax refunds under value-added tax laws do not need to submit value-added tax declaration dossiers in the following cases:
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Program/project owners or main contractors (including operating offices of main contractors in Vietnam), organizations designated by foreign donors to manage programs/projects using non-refundable Official Development Assistance (ODA) capital (including operating offices of donors or organizations managing and implementing programs/projects designated by donors);
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Organizations in Vietnam using non-refundable aid or humanitarian aid money from foreign organizations/individuals to purchase goods/services serving non-refundable aid or humanitarian aid programs/projects in Vietnam;
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Organizations and individuals entitled to diplomatic privileges and immunities in accordance with diplomatic law purchasing goods and services in Vietnam.
Case 3: Taxpayers do not need to submit tax declaration dossiers or other revenue collection dossiers when the tax authority already has sufficient information from national databases, state agencies, the Tax Management Information System, or dossiers provided by competent agencies to determine financial obligations. Cases requesting tax exemption or reduction must still submit declaration dossiers. The catalog of applicable dossiers is publicly disclosed by the tax authority on the Tax Management Information System.
Case 4: Vietnamese parties making income payments to foreign organizations/individuals from investments in international bonds of the Vietnamese Government, or from loans to the State or Government of Vietnam that fall under cases not subject to value-added tax and exempt from corporate income tax under tax laws, do not need to submit tax declaration dossiers.
Case 5: Fee and charge collecting organizations not required to declare fees and charges under fee and charge legislation do not need to submit fee and charge declaration dossiers.
Case 6: Organizations and individuals exempt from natural resource tax that do not fall under cases where the tax authority issues a notice or decision on tax exemption/reduction guided by the Minister of Finance do not need to submit natural resource tax declaration dossiers.
The addition of cases exempt from submitting tax declaration dossiers and other revenue collections demonstrates an ongoing orientation toward simplifying administrative procedures in tax administration. Now, regulations only require setting up declaration dossiers when actual financial obligations requiring management arise. Along with that, promoting regulations that eliminate dossier submission when tax authorities already have complete information from national databases and databases of competent state agencies helps relieve paper burdens for businesses, reduce compliance costs, limit duplicate information provision, and promote digital transformation in tax administration.
VIII. Abolishing certain cases of tax assessment
Compared to specific regulations on tax assessment cases in Article 14 of Decree 126, Decree 252 has recently been amended to refer to cases of tax assessment under the Law on Tax Administration 2025. Accordingly, a number of cases previously serving as grounds for tax authorities to perform tax assessments have been abolished, including:
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Failure to comply with tax inspection decisions within 10 working days from the signing date of the decision, except in cases granted a postponement of inspection time in accordance with regulations.
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Failure to comply with tax audit decisions within 15 days from the signing date of the decision, except in cases granted a postponement of audit time in accordance with regulations.
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Showing signs of absconding or dispersing assets to avoid fulfilling tax obligations.
The abolition of the above cases shows that the scope of applying tax assessment measures has been narrowed down to apply only to cases with direct evidence related to determining taxpayers' tax obligations. Accordingly, tax assessments must be carried out based on evidentiary grounds such as dossiers, books, vouchers, or inaccurate declarations, rather than relying on behaviors or signs not directly attached to determining tax obligations.
IX. Supplementing cases where enforcement measures are not yet applied
Article 65 of Decree 252 has added regulations on cases where enforcement measures are not applied or not yet applied as follows:
Case 1: For tax debt amounts currently subject to tax debt freezing under regulations:
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For cases specified in Points a, b, d, and dd, Clause 1, Article 20 of the Law on Tax Administration, tax management authorities shall not apply enforcement measures during the tax debt freezing period, except where the tax management authority has issued an enforcement decision to execute administrative decisions on tax administration. If the tax management authority discovers that the taxpayer has assets or cash flow to fulfill tax obligations, enforcement will be carried out according to regulations;
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For cases specified in Point c and Point e, Clause 1, Article 20 of the Law on Tax Administration, enforcement measures shall not be applied during the tax debt freezing period. In cases where an enforcement decision has been issued, the tax management authority shall issue a decision terminating the effect of the enforcement decision.
Case 2: Enforcement measures shall not yet be applied to taxpayers (except in cases where taxpayers do not operate at their registered address) when the total tax debt subject to enforcement does not exceed the following thresholds:
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For organizations: VND 3,000,000;
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For households, business households, individuals, and business individuals: VND 1,000,000;
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Enforcement measures shall not be applied to tax debt amounts specified in Clause 7 and Clause 8, Article 48 of the Law on Tax Administration.
X. Specifying the application of enforcement measures requesting the Court to declare bankruptcy
This is a new point specifically regulated by Decree 252 in Article 72, whereby tax management authorities shall submit petitions requesting bankruptcy procedures against enterprises and cooperatives meeting one of the following conditions:
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Enterprises and cooperatives not operating at their registered address for over 03 years from the date the tax authority issues a notice that the taxpayer is not operating at the registered address, and the taxpayer has not submitted a dossier requesting restoration or invalidation of the tax identification number; and the tax management authority has applied one of the enforcement measures specified in Articles 66, 68, 69, 70, and 71 of Decree 252 but failed to recover the tax debt;
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Enterprises and cooperatives subject to enforcement of administrative decisions on tax administration, where the tax management authority has applied enforcement measures to execute administrative decisions on tax administration as prescribed for 03 years or longer without recovering the tax debt.
Furthermore, if the Court issues a notice returning the petition or a decision not to open bankruptcy procedures upon the tax management authority's request, the tax management authority shall apply administrative enforcement measures by revoking business registration certificates, enterprise registration certificates, cooperative registration certificates, cooperative union registration certificates, household business registration certificates, establishment and operation licenses, practice licenses, branch/representative office operation registration certificates, business location registration certificates, or requesting termination or confirmation of e-commerce operation registration.
This regulation contributes to completing the handling mechanism for enterprises no longer capable of fulfilling tax obligations, while ensuring consistency between tax administration law and bankruptcy law.
Decree 252 has supplemented many new regulations aimed at specifying the Law on Tax Administration, while continuing to simplify administrative procedures, enhance the application of information technology, and utilize data in tax management work. The new regulations not only contribute to improving management efficiency for tax authorities but also create conditions for taxpayers to fulfill tax obligations conveniently, transparently, and with reduced compliance costs. Therefore, enterprises and individuals need to proactively review internal tax management processes to promptly update and comply with the new provisions of the Decree.
Decree 252 takes effect from July 1, 2026./.
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