Tax Administration Law 2025 (108/2025/QH15)

Pursuant to the Constitution of the Socialist Republic of Vietnam as amended and supplemented by certain provisions according to Resolution No. 203/2025/QH15;

The National Assembly promulgates the Law on Tax Administration.

Chapter I. GENERAL PROVISIONS

Article 1. Scope of regulation

This law stipulates the management of types of taxes and other revenues belonging to the state budget.

Article 2. Subjects of application

1. Taxpayers include:

a) Organizations, households, business households, individuals, business individuals who are taxpayers according to the provisions of tax law;

b) Foreign organizations, foreign individuals having business activities in Vietnam or having income arising in Vietnam who are taxpayers according to the provisions of tax law;

c) Foreign organizations, foreign individuals having business activities on e-commerce platforms or other digital platforms who are taxpayers according to the provisions of tax law;

d) Organizations, households, business households, individuals, business individuals who pay other revenues belonging to the state budget as prescribed by law;

d) Organizations and individuals implement the deduction and pay on behalf of the deducted tax in accordance with tax laws, tax administration laws, and other relevant legal provisions.

2. Tax management authorities include tax authorities and customs authorities.

3. Tax management officials include tax officials and customs officials.

4. Other relevant state agencies, organizations, and individuals.

5. The Government shall provide detailed regulations for Clauses 1 and 2 of this Article.

Article 3. Classification of taxpayers in tax administration

1. The tax authority shall group taxpayers according to the criteria prescribed in Clause 2 of this Article to determine the priority regime for taxpayers in tax administration, allocate management resources; apply tax management measures, supervise the fulfillment of tax obligations, and tax administration procedures suitable for each taxpayer group; apply methods of analysis and assessment of tax risk levels, compliance with tax laws of taxpayers, and taxpayers' history of complying with the law.

2. The criteria for grouping taxpayers include:

a) Industry, sector, characteristics, mode of operation;

b) Legal form, ownership structure;

c) Scale of operations, revenue size, budget contributions;

d) Level of compliance and history of compliance with tax laws of the taxpayer;

e) Other criteria as prescribed by the Minister of Finance.

3. The Minister of Finance shall provide detailed regulations on this Article.

Article 4. Interpretation of Terms

In this Law, the terms below are understood as follows:

1. Tax is a mandatory payment to the state budget by organizations, households, business households, individuals, and individual businesses as prescribed by tax laws.

2. Other revenues belonging to the state budget managed by the tax authority (hereinafter referred to as other revenues) are the revenues specified in Point b, Clause 1, Article 38 of this Law.

3. Other revenues belonging to the state budget not managed by the tax authority are the revenues specified in Clause 6, Article 39 of this Law.

4. Tax arrears are taxes, other revenues, late payment fees, fines managed by the tax authority that taxpayers have not paid to the state budget when the payment deadline prescribed has expired.

5. The tax management information system is a centrally processing system, integrated on a digital data platform, with functions to collect, process, store, update, and manage tax information and data in order to provide digital services for taxpayers; support tax management electronically; and apply technology to maximally automate business processes.

6. The taxpayer's office is the location where the taxpayer conducts part or all of their business activities, including the main office, branch, store, production site, place for goods storage, place for assets used for production and business; residence or place where tax obligations arise.

7. The tax code is a series of numbers or numbers with characters assigned by the tax authority for each taxpayer to manage taxes.

8. Tax period, other levy period (hereinafter referred to as tax period) is the time frame to determine the amount of tax and other levies to be paid to the state budget in accordance with tax law, tax administration law, and other relevant legal regulations, including periods based on each occurrence, month, quarter, year, or settlement period.

9. Tax records, records of other receipts (hereinafter referred to as tax records) are records for tax registration, tax declaration, declaration of other receipts, tax payment, payment of other receipts, extension of tax declaration submission, extension of submission of declaration of other receipts, tax refund records, refund of other receipts, tax exemption records, exemption of other receipts, tax reduction records, reduction of other receipts, records of non-taxable amounts, records of no tax collection, records of tax arrears write-off, records of tax debt cancellation, records of late payment exemption, penalty exemption records, records of no late payment interest, records of tax payment extension, records of extension for payment of other receipts, records of extension for payment of tax arrears, records of installment payment of tax arrears, and customs records.

10. Compulsory enforcement of administrative decisions on tax management is the application of measures according to the provisions of this Law and other relevant legal regulations to compel taxpayers to fulfill their tax obligations.

11. Tax risk is the risk that taxpayers do not comply with the law, leading to loss of state budget revenue.

12. Risk management in tax administration is the process by which tax authorities apply a system of measures, operational procedures, and data analysis tools to identify, assess, and classify the level of tax risk according to criteria specified by the tax authorities, in order to allocate resources, apply appropriate management measures, focus on handling high-risk cases, and timely control the risk of legal violations in tax administration.

13. Compliance management in tax administration is the use by tax authorities of records, information, documents, and data about taxpayers to monitor and evaluate the level of compliance with tax laws and to apply appropriate management measures to encourage and support voluntary compliance, apply preferential treatment to cases of good compliance, and strengthen supervision and timely handling of non-compliant cases.

14. Fulfilling tax obligations is the payment of the full amount of taxes, other revenues, late payment charges, and administrative penalties related to tax administration.

15. Commercial databases are collections of information, economic, financial, and commercial data collected, processed, standardized, and provided on the market by data business organizations.

16. Taxpayer information is information and data about taxpayers and information related to taxpayers' tax obligations provided by taxpayers, provided by competent state agencies, organizations, or individuals, or collected by tax management authorities during the tax management process.

17. Related parties are parties that directly or indirectly participate in the management, control, or capital contribution of an enterprise; parties jointly subject to direct or indirect management or control by an organization or individual; parties that jointly have an organization or individual participating in capital contribution; enterprises managed and controlled by individuals who are members of the same family.

18. Related-party transactions are transactions arising between parties that have a related-party relationship.

19. Independent transactions are transactions arising between parties that do not have a related-party relationship.

20. The arm's length principle is the principle applied in declaring and determining the price of related-party transactions of taxpayers that have related-party transactions, whereby the conditions in the related-party transactions are determined to be equivalent to the conditions in comparable independent transactions in the market.

21. Force majeure cases are cases in which taxpayers suffer material damage due to natural disasters, catastrophes, epidemics, fires, sudden accidents, and other force majeure cases as prescribed by the Government.

Article 5. Tax management content

1. The tax authority manages taxes according to taxpayer subgroups.

2. Tax management content includes:

a) Tax registration; tax declaration, tax calculation, tax deduction; tax payment, late payment interest, penalties; tax assessment; tax refund; handling of tax money, late payment interest, and overpaid penalties; tax exemption; tax reduction; non-taxable; non-collection of tax; tax debt rescheduling; tax debt cancellation; waiver of late payment interest; waiver of penalties; calculation of late payment interest, non-calculation of late payment interest; extension for payment of tax, late payment interest, penalties; extension for submitting tax declaration documents; gradual payment of tax debt; enforcement of administrative decisions on tax management;

b) Propagation, taxpayer support; risk management, compliance management;

c) Taxpayer information management;

d) Invoice and document management;

e) Tax inspection; implementation of measures to prevent, counteract, and stop violations of tax law; handling of administrative violations in tax management; resolution of tax complaints and denunciations;

e) International cooperation on taxation; tax administration according to international tax treaties, international tax agreements to which the Socialist Republic of Vietnam is a member or signatory, and international tax commitments.

3. The tax authority applies the tax administration provisions specified in Clause 2 of this Article to manage other revenue items in accordance with the provisions of this Law and other relevant legal regulations.

Article 6. Principles of tax administration

1. Tax administration must ensure the principles of publicity, transparency, equality, centering on serving taxpayers, safeguarding the lawful rights and interests of taxpayers, and enhancing the effectiveness and efficiency of state budget management.

2. Taxpayers have the obligation to pay taxes and other amounts belonging to the state budget as prescribed by tax law and other legal regulations. Taxpayers self-determine their tax obligations and other amounts belonging to the state budget that must be paid, self-declare taxes and other amounts belonging to the state budget, and self-pay taxes and other amounts belonging to the state budget to the state budget in accordance with tax law, tax administration law, and other relevant legal provisions, except in cases where the tax authority calculates taxes or other amounts and issues tax notices or other collection notices as prescribed by law.

3. The tax authorities, state agencies, and other state organizations assigned with the task of managing the state budget revenue shall perform tax administration and management of other amounts belonging to the state budget in accordance with the provisions of this Law and other relevant legal regulations.

4. Principles applied in tax administration:

a) The principle that the nature of activities and transactions determines tax obligations in tax administration aims to identify the nature of taxpayers' production and business transactions and activities as a basis for determining tax obligations and other revenues, ensuring that taxpayers' transactions reflect the true commercial, economic, and financial nature, regardless of the form of the transaction as presented in contracts or documents between the taxpayer and related parties;

b) The principle of independent transactions;

c) The principle of risk-based management using the level of risk to efficiently utilize resources and improve management effectiveness;

d) The principle of compliance-based management according to the taxpayer's level of compliance to encourage voluntary fulfillment of tax obligations;

e) The principle of tax administration according to international practices suitable for Vietnam's conditions.

Article 7. Confidentiality and Disclosure of Taxpayer Information

1. Tax authorities, tax officials, individuals who were formerly tax officials, agencies providing or exchanging taxpayer information, organizations providing tax procedure services (hereinafter referred to as tax agents), organizations providing customs procedure services (hereinafter referred to as customs procedure agents) must keep taxpayer information confidential, except in cases where tax authorities provide or disclose taxpayer information as specified in Clauses 2 and 3 of this Article.

2. Tax authorities provide taxpayer information in the following cases:

a) Providing information to investigative agencies, the Procuracy, the Courts, inspection agencies, the State Audit Office, and other state management agencies upon written request to serve prosecutorial, inspection, examination, and audit activities in accordance with the law;

b) Provide to other competent state agencies when requested in writing as prescribed by law;

c) Provide to the foreign tax authorities in accordance with international tax treaties, international tax agreements of which the Socialist Republic of Vietnam is a member or a signatory.

3. The tax authorities are required to disclose taxpayer information in the following cases:

a) Tax evasion, other revenue; procrastinating in paying taxes, other revenue, late payment fees, fines on time; owing taxes, other revenue, late payment fees, fines;

b) Violating tax laws that affect the rights and obligations of other organizations and individuals to pay taxes;

c) Failing to comply with the requests of tax authorities as prescribed by law.

4. Agencies, organizations, and individuals provided with information by the tax authorities under the cases prescribed in Clause 2 of this Article, tax authorities, other state agencies, and related organizations domestically and internationally, when performing the duties and responsibilities of providing, sharing, and exchanging taxpayer information for tax administration purposes as prescribed in Articles 38, 39, and 40 of this Law, must use the information for the correct purpose and keep the information confidential in accordance with this Law and other relevant legal regulations.

5. The Government shall specify in detail Point c, Clause 2, and Clause 3 of this Article.

Article 8. Acts Prohibited in Tax Administration

1. Collusion, connection, and cover-up between taxpayers and tax officials, tax management agencies to transfer prices, evade taxes, other revenues, fraud, and exploit tax money or state budget funds. Abuse of position and authority to disclose or leak taxpayer information against regulations. Falsifying inspection results, handling violations of tax laws incorrectly. Causing harassment or trouble to taxpayers. Exploiting to embezzle or unlawfully use tax money or other revenues.

2. Intentionally failing to declare or declaring taxes or other revenues incompletely, untimely, or inaccurately regarding the amount of taxes or other revenues payable, the amount of taxes or other revenues exempted, reduced, refunded, or not collected. Obstructing tax officials from performing their duties. Resisting, delaying, or failing to provide information and documents for tax inspection and supervision of other revenues.

3. Using another taxpayer's tax code to commit illegal acts or allowing others to use one's tax code in violation of the law.

4. Selling goods or providing services without issuing invoices as prescribed by law; using illegal invoices or documents, misusing invoices or documents, forging invoices or documents to carry out illegal acts. Illegally creating electronic invoices or documents or serving acts of violation in the field of tax administration.

5. Falsifying, misusing, illegally accessing, or destroying taxpayer information systems. Providing or spreading false information that affects the reputation and operations of tax authorities, taxpayers, or the Tax Management Information System.

Article 9. Building the tax administration force

1. The tax administration force is built to be clean and strong; having public service ethics, a spirit of serving taxpayers, complying with discipline and administrative regulations; equipped with and mastering modern techniques, operating effectively and efficiently.

2. Tax management officials are applied with a system of titles, standards, salaries, benefits, insignia, ranks, uniforms, and signs of tax management officials to ensure tax administration work, encourage, and enhance responsibility, professionalism, and the effectiveness of public service performance.

3. Tax management agencies are responsible for training and building a team of tax management officials to perform tax management functions as prescribed by law.

4. The State ensures financial resources for the activities of the tax management force and tax administration agencies; in which priority is given to allocating the annual state budget to build and operate information technology systems, digital transformation in tax management, e-invoicing, facilities, equipment, and specialized tasks serving work to enhance tax management efficiency.

5. The Government shall provide detailed regulations on Clauses 2 and 4 of this Article.

Chapter II. TAX MANAGEMENT FUNCTIONS

Section 1. TAX REGISTRATION

Article 10. Tax Registration

1. The scope of tax registration includes initial tax registration; notification of changes in tax registration information; notification when suspending activities or business; termination of tax code validity; restoration of tax code.

2. Enterprises, cooperatives, cooperative unions, cooperative groups, dependent units, other organizations, business households, and individual businesspersons shall carry out tax registration simultaneously with business registration, cooperative registration, cooperative union registration, cooperative group registration, business household registration, or registration for operation and business under the one-stop-shop mechanism.

3. Other cases not specified in Clause 2 of this Article shall carry out tax registration directly with the tax authority.

4. The time limit for tax registration; responsibilities of taxpayers, tax management agencies, state agencies, organizations, and individuals related to tax registration shall be implemented in accordance with Government regulations.

5. The Minister of Finance shall provide detailed regulations for Clauses 1 and 3 of this Article.

Article 11. Tax identification number

1. The tax identification number of individuals, households, business households, and business individuals is the personal identification number of the individual, head of the household, head of the business household, or business individual, issued in accordance with the provisions of the law on personal identification.

2. The tax identification number of enterprises, cooperatives, cooperative unions, cooperative groups, dependent units, and other organizations specified in Clause 2, Article 10 of this Law is the number of the enterprise, cooperative, cooperative union, cooperative group, dependent unit, or other organization issued in accordance with the provisions of the law.

3. The tax identification number of taxpayers not prescribed in Clauses 1 and 2 of this Article is the number issued by the tax authority to be used throughout the activity process from the time of initial tax registration until the tax identification number is terminated.

4. The tax code of the organization or individual responsible for withholding and remitting on behalf of other taxpayers shall be implemented in accordance with the regulations of the Minister of Finance.

5. The tax code is used as follows:

a) It is recorded on invoices, documents, dossiers, and materials when carrying out business transactions, performing administrative procedures related to taxes, and opening accounts at credit institutions, branches of foreign banks, payment service providers, and intermediary payment service providers;

b) It is used in tax management; exchanging, sharing, and providing information about taxpayers with the tax management authorities.

6. The Government shall detail the provisions of Clause 5 of this Article.

7. The Minister of Finance shall detail Clauses 1, 2, 3, and 4 of this Article.

Section 2. TAX DECLARATION, OTHER REVENUES;

Section 2. TAX DECLARATION, OTHER REVENUES; TAX CALCULATION, OTHER REVENUES; TAX WITHHOLDING

Article 12. Tax declaration, other revenues; tax calculation, other revenues; tax withholding

1. Taxpayers must accurately, honestly, and fully declare all contents in the tax declaration dossier, other revenue types for each type of tax and other revenue, and self-calculate the amount of tax and other revenue payable, except in cases where tax calculation, other revenue, tax notices, or other revenue are carried out by the tax authority in accordance with government regulations.

2. Foreign organizations and foreign individuals conducting business on e-commerce platforms, other digital platforms, and other services must directly or authorize the declaration and payment of taxes and other revenue in Vietnam, except in cases prescribed in Clause 3 of this Article.

3. Withholding, declaring on behalf, payment on behalf:

a) Organizations and individuals subject to withholding and payment on behalf of deducted taxes under the tax law must withhold the tax from the taxpayer and declare and pay the deducted tax.

b) Organizations and individuals in cases of filing or paying taxes and other revenues on behalf of taxpayers in accordance with tax laws and other relevant legal regulations must perform the filing and payment on behalf of the taxpayer;

c) Taxpayers are not required to pay taxes or other revenues that have been deducted, filed, or paid on their behalf.

4. Taxpayers who are unable to submit tax or other revenue declarations on time due to force majeure as prescribed in Clause 21, Article 4 of this Law shall be granted an extension as follows:

a) In cases of monthly, quarterly, or annual tax declarations and other revenue, for each occurrence of tax or other revenue obligation, the extension period shall not exceed 30 days from the deadline for submitting the tax declaration or other revenue documents.

In cases of finalizing tax declarations or other revenue, the extension period shall not exceed 60 days from the deadline for submitting the final tax declaration or other revenue documents;

b) In cases where it is necessary to extend the deadline for submitting tax declaration dossiers or other revenue items specified in point a of this clause, the Government shall regulate appropriately in accordance with the actual situation.

5. Taxpayers who detect errors or omissions in the tax declaration dossiers or other revenue items that have been submitted to the tax authorities are allowed to submit supplementary tax declaration dossiers or other revenue items within 05 years from the expiration date of the submission deadline for the tax declaration dossiers or other revenue items of the taxable period that contains errors or omissions in the following cases:

a) Before the tax authority or competent authority announces the decision on inspection or audit;

b) The dossiers are not within the scope or period of tax inspection or audit as stated in the inspection or audit decision;

c) The dossiers are not cases where the investigative agency requests that supplementary tax declaration dossiers or other revenue items not be submitted to serve the investigation of the case;

d) If the taxpayer discovers that the submitted tax declaration contains errors or omissions related to the scope or period that has been audited or inspected, resulting in an increase in the tax payable, a reduction in the tax that has been exempted, reduced, refunded, a reduction in the deductible tax, or a reduction in the overpaid tax, the taxpayer is allowed to supplement the explanation dossier with the tax authority. The tax authority is responsible for reviewing the explanatory dossier related to the scope and period that has been audited or inspected of the taxpayer. If the tax authority accepts the taxpayer's explanatory dossier, it shall issue a notification approving the taxpayer to adjust the tax declaration.

Taxpayers are handled according to regulations as in cases where the tax authorities or competent agencies detect during inspection or examination. Tax inspection and examination officers related to the explanatory files are responsible for errors and omissions not fully detected during inspection in cases of non-compliance with the provisions at point n, clause 1, Article 38 of this Law;

d) Cases are handled according to the conclusions or decisions of competent state agencies concerning the determination of the taxpayer's tax obligations. In cases where taxpayers submit supplementary declarations that increase the tax payable or reduce the tax to be deducted, exempted, reduced, or refunded, they are handled according to regulations as in cases where the tax authorities or competent agencies detect during inspection or examination;

e) The government regulates cases in which the investigative agency requests that no supplementary tax declaration or other revenue declaration be made in order to serve the investigation of a case, and the responsibility of the investigative agency to notify the tax authority upon completion of the request related to the case, as prescribed in point c of this clause, and cases of supplementary declarations according to the conclusions or decisions of competent state agencies related to determining the tax obligations of taxpayers, as prescribed in point đ of this clause.

6. For exported and imported goods, customs documents as prescribed by the Customs Law are used as tax declaration documents. Tax declaration, supplementary declaration, tax declaration submission deadlines, customs authority receiving tax declaration documents, and the exchange rate for calculating tax on exported and imported goods are implemented in accordance with the provisions of the law on customs.

7. The currency for declaring taxes and other revenues is the Vietnamese Dong; the currency for calculating taxes and other revenues is the Vietnamese Dong. The government stipulates cases where declaration and calculation can be made in foreign currency.

8. The Government shall provide detailed regulations on clauses 1, 2, 3, 5, 6, 7 and point b, clause 4 of this Article and the following matters: cases not required to submit tax declaration dossiers, other revenue items; tax calculation period; deadline for submitting tax declaration dossiers and other revenue items, except for the cases stipulated in clause 9 of this Article; declaration of taxes and other revenue items, calculation of taxes and other revenue items, payment of taxes and other revenue items in petroleum activities and petroleum sales; exchange rates used for tax declarations and other revenue items conversion; declaration and determination of taxable prices for related-party transactions, reporting of multinational profits; allocation of tax obligations and other revenues to be paid; procedures for receiving and processing dossiers in cases where the tax authority calculates taxes and other revenue items, and issues tax notifications and other revenue items.

9. The Minister of Finance shall stipulate in detail Point a, Clause 4 of this Article and the following contents: the deadline for submitting tax declaration dossiers for agricultural land use tax, non-agricultural land use tax, and other revenues; the tax calculation period for each type of tax and other revenue; tax declaration for taxes and other revenues; tax calculation for taxes and other revenues; tax declaration dossiers for taxes and other revenues; the form of submitting tax declaration dossiers for taxes and other revenues; tax authorities receiving and processing tax declaration dossiers for taxes and other revenues.

Article 13. Tax declaration for taxes and other revenues; tax calculation for taxes and other revenues; tax deduction for business households and business individuals

1. For value-added tax and personal income tax:

a) In the case of business households or individual businesspeople who determine that their annual revenue from the production and business of goods and services falls under non-taxable subjects, or subjects not required to pay tax according to the provisions of the law on value-added tax and personal income tax, the business household or individual businessperson must report the actual revenue arising during the year to the tax authority;

b) In the case of business households or individual businesspeople who determine that their annual revenue from the production and business of goods and services falls under taxable subjects, or subjects required to pay tax according to the provisions of the tax law, the business household or individual businessperson must determine the amount of value-added tax and personal income tax payable in accordance with the provisions of the law on value-added tax and personal income tax.

In the case of business households and individual businesses using electronic invoices, electronic invoices created from cash registers connected to data with the tax authority, the tax management information system automatically generates tax declarations to support business households and individual businesses in tax declaration and tax calculation based on electronic invoice databases, tax management databases, and other database sources obtained by the tax authority from other state agencies, organizations, and individuals.

2. For other types of taxes and other revenue:

Business households and individual businesses self-determine the amount of tax and other revenue payable in accordance with the provisions of tax law and other relevant legal regulations.

3. Business households and individual business owners shall declare taxes and calculate taxes for each type of tax according to the tax period. The tax authority shall provide information based on the tax management database to support business households and individual business owners in tax declaration and tax calculation.

4. For business households and individual business owners who conduct business on e-commerce platforms or other digital platforms:

a) In the case of business activities on e-commerce platforms or other digital platforms that have online ordering and payment functions, the operators of e-commerce platforms or other digital platforms (domestic or foreign) are responsible for withholding, declaring on behalf, and paying on behalf the withheld tax of the business households or individual business owners;

b) In the case of having business activities on e-commerce platforms or other digital platforms that do not have online ordering and payment functions, business households and individual businesses directly declare, calculate, and pay taxes according to regulations.

5. The Government shall provide detailed regulations on this Article and the following contents: the settlement of taxes and handling of overpaid taxes and other collections; the scope of responsibility and methods by which the administrators of e-commerce platforms and other digital platforms implement the deduction, declaration on behalf, and payment on behalf of the taxes already withheld by business households and individual businesses; the responsibility of declaring and paying taxes on behalf by organizations in cases of business cooperation with business households and individual businesses, signing contracts with business households and individual businesses to act as agents selling at the correct price for lottery tickets, insurance, and multi-level marketing sales.

6. The Minister of Finance shall stipulate the dossiers, procedures for revenue declaration, tax declaration, tax payment and tax refund, and the accounting regime applicable to business households and individual businesses.

Section 3

PAYING TAXES, OTHER RECEIVABLES, LATE PAYMENT FEES, PENALTIES; EXTENSION OF TIME TO PAY TAXES, OTHER RECEIVABLES, LATE PAYMENT FEES, PENALTIES; HANDLING EXCESS PAYMENT OF TAXES, OTHER RECEIVABLES, LATE PAYMENT FEES, PENALTIES; HANDLING LATE PAYMENT OF TAXES, OTHER RECEIVABLES

Article 14. Paying taxes, other receivables, late payment fees, penalties; extension of time to pay taxes, other receivables, late payment fees, penalties

1. Deadline for paying taxes, other receivables, late payment fees, penalties:

a) In cases where the taxpayer self-assesses taxes and other receivables, the deadline for paying taxes and other receivables is no later than the last day of the deadline for submitting the tax declaration and other receivables. In cases of supplementary tax declarations or other receivable filings, the deadline for paying taxes and other receivables is the deadline for submitting the tax declaration and other receivables for the relevant tax period that contains errors or omissions. For cases of provisional quarterly payments, the payment deadline is implemented according to the Government's regulations;

b) In the case where the tax authority calculates taxes or other levies, issues a tax payment notice or other levy notice, or issues a decision on tax or other levy handling, the deadline for paying taxes or other levies, late payment interest, and fines is the deadline stated in the notice or decision of the tax authority in accordance with the law. In the event that a competent state agency issues a document on handling taxes or other levies, the deadline for paying taxes or other levies, late payment interest, and fines is the deadline stated in the document of the competent state agency.

During the period of handling complaints or lawsuits of taxpayers regarding the amount of tax, other fees, late payment interest, or fines owed, taxpayers must still pay the full amount of tax, other fees, late payment interest, or fines owed, except in cases where the competent state agency decides to temporarily suspend the implementation of the tax payment notice, other fee, decision, or administrative document regarding tax, other fees, late payment interest, or fines from the tax authority or competent state agency;

c) For exported and imported goods subject to tax under the provisions of tax law, the tax payment deadline is implemented according to the provisions of the Law on Export and Import Tax; in cases where tax amounts arise after customs clearance or release of goods, the deadline for paying the incurred tax shall be implemented according to the provisions of the Minister of Finance.

2. Taxpayers shall pay taxes, other revenues, late payments, and fines by one of the following methods:

a) Payment electronically through the Tax Management Information System; the Public Service Online System of the State Treasury; electronic payment services of a payment service provider, intermediary payment service provider, or other service organization directly or indirectly connected to the Tax Management Information System of the tax authority as prescribed by law;

b) Direct payment at a payment service provider, intermediary payment service provider, or other service organization directly or indirectly connected to the Tax Management Information System of the tax authority; a competent state agency as prescribed by law; tax authorities; or an organization delegated by the tax authority to collect taxes.

3. The currency used to pay taxes and other revenues is the currency used to declare taxes and other revenues as prescribed in Clause 7, Article 12 of this Law. Taxpayers must pay taxes and other revenues in the currency in which they declare them.

4. After paying taxes, other revenues, late payment fees, and fines, taxpayers are issued a payment receipt. In cases where the amount of taxes, other revenues, late payment fees, and fines to be paid has been provided with an identification code by the tax administration, taxpayers must pay according to the identification code of the payable amount.

Agencies and organizations collecting taxes, other revenues, late payment fees, and fines as prescribed in Clause 2 of this Article, when issuing a payment receipt to taxpayers, shall simultaneously transfer information to the tax administration for recording and settlement of tax obligations, other revenues, late payment fees, and fines for taxpayers.

The identification code for a payable amount is a sequence of characters generated on the Tax Management Information System, unique to each payable amount of the taxpayer.

5. The determination of the tax payment date, other receipts, late payment fees, and penalties is regulated as follows:

a) In case of electronic payment, the tax payment date, other receipts, late payment fees, and penalties are the date stipulated by the agency or organization specified in point a, clause 2 of this Article, when the funds are debited from the account of the taxpayer or the payer on behalf and recorded on the payment voucher;

b) In case of direct payment, the tax payment date, other receipts, late payment fees, and penalties are the date stipulated by the agency or organization specified in point b, clause 2 of this Article, when the funds are received from the taxpayer and recorded on the collection voucher.

6. The payment of fines for exported and imported goods shall be carried out in accordance with the provisions of the law on handling administrative violations. The extension of the payment of fines for exported and imported goods shall be carried out in accordance with the provisions of this Law.

7. Taxpayers are entitled to an extension of tax payment, other revenues, late payment interest, and fines in the following cases:

a) Suffering material damage that directly affects production and business due to force majeure as prescribed in this Law;

b) Being forced to suspend activities due to the relocation of production or business establishments as required by competent state authorities, which affects the results of production and business;

c) Extension of tax payment, other revenues, late payment interest, and fines in special cases as prescribed by the Government. The extension of tax payment, other revenues, late payment interest, and fines does not lead to an adjustment of the state budget estimate that has been approved by the National Assembly.

Taxpayers who are granted an extension under the provisions of this clause are not required to pay late payment interest on the amount of tax debt that is extended during the extension period.

8. The Government shall stipulate in detail Clause 1 of this Article and the following contents: the time frame for agencies and organizations to collect taxes, other collections, late payment interest, and penalties to be paid into the state budget; the extension period for paying taxes, other collections, late payment interest, and penalties; the dossiers and procedures for extending the payment of taxes, other collections, late payment interest, and penalties in the case specified in Point c, Clause 7 of this Article.

9. The Minister of Finance shall stipulate in detail items 2, 3, 4, 5, 7 of this Article and the following contents: the review and handling of tax payment documents, other revenue, late payment fees, fines, the resolution of dossiers for tax payment extension, other revenue, late payment fees, fines, except as stipulated in point c, clause 7 of this Article.

Article 15. Handling of excess tax, other revenue, late payment fees, and fines

1. Excess tax, other revenue, late payment fees, and fines are amounts of tax, other revenue, late payment fees, and fines paid that are greater than the amounts of tax, other revenue, late payment fees, and fines that must be paid.

2. Taxpayers who have overpaid taxes, other revenues, late payment fees, or penalties can offset the overpaid amounts against taxes, other revenues, late payment fees, or penalties that are payable, or receive a refund of overpaid taxes, other revenues, late payment fees, or penalties when the taxpayer has no outstanding tax debt. Offsetting within the same type or between different types of taxes, other revenues, late payment fees, or penalties is carried out automatically by the Tax Management Information System or upon the taxpayer's request according to the guidance of the Minister of Finance.

In cases where a taxpayer has overpaid value-added tax when importing goods and has declared the deduction of the overpaid amount with the tax authority, the handling of the deducted and overpaid tax amount shall be conducted in accordance with the regulations of the Minister of Finance.

3. In cases where the taxpayer requests a refund of overpaid taxes, other contributions, late payment charges, or penalties, it shall be carried out in accordance with the provisions of Article 18 of this Law.

4. Refunds of overpaid taxes, other contributions, late payment charges, or penalties shall not be made in the following cases:

a) The taxpayer refuses to receive the overpaid taxes, other contributions, late payment charges, or penalties;

b) The overpaid taxes, other contributions, late payment charges, or penalties exceed a period of 10 years from the date of payment into the state budget, and the taxpayer neither offsets these against tax liabilities, other contributions, late payment charges, or penalties nor requests a refund.

5. The Minister of Finance shall provide detailed regulations on this Article and the following contents: dossiers, procedures, authority to handle tax amounts, other collections, late payment amounts, excess payment fines; the timing for determining tax amounts, other collections, late payment amounts, excess payment fines; cases of offsetting conducted automatically by the Tax Management Information System and cases of offsetting at the request of the taxpayer.

Article 16. Handling of late payment of taxes and other collections

1. Cases that must pay late payment interests include:

a) Taxpayers who pay taxes or other collections later than the deadlines for payment or the extended payment deadlines specified in Article 14 of this Law;

b) Taxpayers who supplement their tax declaration dossiers, other collections that increase the amount of tax or other collections to be paid or reduce the amount of tax or other collections that have been exempted, reduced, refunded, or not collected;

c) Tax authorities, state authorities with inspection and examination powers, detect that the taxpayer underreported the amount of tax or other revenue payable, or detect that the amount of tax or other revenue refunded, exempted, reduced, or not collected is greater than the amount of tax or other revenue that can be refunded, exempted, reduced, or not collected;

d) Cases eligible for installment payment of tax debt as prescribed in Clause 6, Article 48 of this Law;

đ) Cases prescribed in Clause 8, Article 44 of this Law;

e) Cases not subject to administrative sanctions for tax management violations under the provisions of Point a, Clause 2, Article 44 regarding the acts prescribed in Clause 2, Article 45 of this Law, and cases prescribed in Point b, Clause 2, Article 44 of this Law.

g) Agencies and organizations entrusted by the tax authorities to collect taxes or other revenues, and agencies and organizations assigned to manage revenues belonging to the state budget that delay remittance to the state budget for the amounts collected must pay late payment interest on the delayed amounts according to the regulations;

h) Agencies and organizations that are subject to tax deduction, tax payment, or payment of other revenues on behalf of taxpayers under tax laws and other relevant legal regulations, if they fail to pay fully or on time according to the law, are responsible for paying late payment interest on behalf of the taxpayer according to the regulations;

i) The payment of late payment interest for exported or imported goods that are taxable and whose taxes are guaranteed by a credit institution must be carried out in accordance with the provisions of the law on export and import taxes.

2. The calculation rate of late payment fees and the period for calculating late payment fees are stipulated as follows:

a) The late payment fee rate is 0.03% per day calculated on the amount of tax, other revenues payable late under the management of the tax authority, and 0.03% per day calculated on the amount of tax payable late under the management of the customs authority;

b) The period for calculating late payment fees is carried out in accordance with the Government's regulations.

3. Taxpayers shall self-determine the amount of late payment fees according to the provisions in clauses 1 and 2 of this Article and pay into the state budget as prescribed. After 30 days from the date the taxpayer pays the tax, other revenues, or fines but has not determined the late payment fee, the tax administration authority shall determine the late payment fee and notify the taxpayer.

4. In the case that 30 days have passed since the tax payment deadline or the payment deadline for other dues, and the taxpayer has not yet paid the owed tax, the tax authority shall notify the taxpayer of the amount of tax debt and the number of days of late payment.

5. A taxpayer who falls under the case of having to pay late payment fees as stipulated in Clause 1 of this Article shall be exempt from late payment fees if it falls under the case of force majeure as stipulated in Clause 21, Article 4 of this Law.

6. The Government shall regulate the following contents: adjusting the rate for calculating late payment fees as stipulated in Point a, Clause 2 of this Article in accordance with the socio-economic situation of each period, the period for calculating late payment fees, cases that are not subject to late payment fees, cases not yet subject to late payment fees, and adjustment of late payment fees.

7. The Minister of Finance shall stipulate the following contents: dossiers, order, procedures, authority for handling late payment of taxes, other revenues, exemption from late payment fees, and non-collection of late payment fees as prescribed in this Article.

Article 17. Fulfillment of tax payment obligations

1. Fulfilling tax obligations in case of dissolution, bankruptcy, cessation of operations, or inactivity at the registered address:

a) Fulfilling tax obligations in the case of a company, cooperative, or cooperative union being dissolved is carried out in accordance with the provisions of the law on enterprises, the law on credit institutions, the law on insurance business, the law on cooperatives, and other relevant legal regulations;

b) Fulfilling tax obligations in the case of a company, cooperative, or cooperative union going bankrupt is carried out in accordance with the provisions of the law on recovery and bankruptcy;

c) If a private enterprise, a single-member limited liability company, or a partnership ceases operations or does not operate at the registered address and has not fulfilled its tax obligations, the owner of the private enterprise, the owner of the single-member limited liability company, or the general partner shall fulfill the tax obligations in accordance with the provisions of enterprise law; if a limited liability company with two or more members or a joint-stock company ceases operations or does not operate at the registered address and has not fulfilled its tax obligations, the contributing shareholders or contributing members shall be responsible for fulfilling the tax obligations in accordance with the provisions of enterprise law;

d) If a business household or an individual business ceases operations or does not operate at the registered address for production and business and has not fulfilled tax obligations, the remaining tax debt shall be the responsibility of the business household owner or individual to complete the tax obligations;

d) If a taxpayer has a dependent unit that ceases operations or does not operate at the registered address and has not fulfilled tax obligations, they shall be responsible for completing the tax obligations of the dependent unit;

e) The owner of a private enterprise, the owner of a single-member limited liability company, a general partnership member, a business household owner, or an individual businessperson is responsible for completing tax obligations and related obligations concerning the tax records of the private enterprise, single-member limited liability company, partnership company, business household, or individual business that does not operate at the registered address.

2. Fulfill tax obligations and obligations related to tax records in the case of reorganizing a business, cooperative, or cooperative union:

a) Enterprises, cooperatives, and cooperative unions that are being divided are responsible for fulfilling tax payment obligations and other obligations related to tax records before carrying out the division of the enterprise, cooperative, or cooperative union. In case the tax payment obligations have not been fulfilled, the newly established enterprises, cooperatives, or cooperative unions from the divided enterprise, cooperative, or cooperative union are responsible for inheriting the rights and fulfilling the tax payment obligations;

b) Enterprises, cooperatives, and cooperative unions that are split, merged, or consolidated are responsible for fulfilling tax payment obligations and other obligations related to tax records before the split, merger, or consolidation. In case the tax payment obligations have not been fulfilled, the enterprises, cooperatives, and cooperative unions being split, and the enterprises, cooperatives, and cooperative unions created from the split; the enterprises, cooperatives, and cooperative unions that are merged; the enterprises, cooperatives, and cooperative unions receiving the consolidation are responsible for inheriting the rights and fulfilling the tax payment obligations.

c) Enterprises undergoing a change of enterprise type are responsible for fulfilling tax payment obligations and other obligations related to tax records before the conversion. In case the tax payment obligations have not been fulfilled, the enterprise after the conversion is responsible for inheriting the rights and fulfilling the tax payment obligations.

d) The reorganization of enterprises, cooperatives, and cooperative unions does not change the deadlines for tax payments and other contributions of the reorganized enterprises, cooperatives, and cooperative unions. In case the reorganized enterprises, cooperatives, and cooperative unions, or newly established enterprises, cooperatives, and cooperative unions do not pay taxes and other contributions in full according to the prescribed deadlines, they will be sanctioned in accordance with the provisions of law.

3. Fulfillment of tax obligations in cases where the taxpayer is a deceased person, a person declared dead or missing by the Court, or a person who has lost civil act capacity:

a) The heir or the person assigned to manage the estate shall fulfill the tax obligations of the deceased, the person declared dead by the Court in the part of the deceased’s estate, the person declared dead by the Court leaving or in the portion of the assets the heir receives at the time of inheritance. In the case of no heir or all heirs refusing to accept the inherited estate, fulfilling the tax obligations of the deceased or the person declared dead by the Court shall be carried out according to the provisions of civil law;

b) The manager of the assets of a person who has lost legal capacity shall fulfill the tax obligations of the person declared by the Court to have lost legal capacity in the part of that person’s assets;

c) In the case where the court issues a decision to annul the decision declaring a person as deceased or legally incapacitated, the amount of tax debt that was written off according to the provisions of Article 21 of this Law shall be restored, but late payment fees shall not be calculated for the period during which the person was declared deceased or legally incapacitated;

d) The manager of the property of a person declared missing must fulfill the tax obligations of the person declared missing by the court using that person’s assets according to the court's decision.

4. Taxpayers are responsible for fulfilling tax obligations in the event of a change of headquarters address that leads to a change in the managing tax authority, except in cases due to changes in administrative boundaries as prescribed by law.

5. Cases that require fulfillment of tax obligations before leaving the country include:

a) Business individuals, household business owners, individuals who are beneficial owners of enterprises, and individuals who are legal representatives of enterprises, cooperatives, or cooperative unions in cases subject to enforced execution of administrative decisions on tax management who have not fulfilled their tax obligations;

b) Business individuals, household business owners, individuals who are beneficial owners of enterprises, and individuals who are legal representatives of enterprises, cooperatives, or cooperative unions who are no longer operating at the registered address and have not fulfilled their tax obligations;

c) Individuals who are Vietnamese citizens leaving the country to settle abroad, Vietnamese citizens residing abroad, and foreigners who have not fulfilled their tax obligations.

The government stipulates the amount of outstanding tax and the period of indebtedness according to thresholds for applying measures to temporarily suspend exit from the country in accordance with the laws on exit and entry.

6. Fulfill tax payment obligations in the case of transferring investment projects, transferring capital:

a) Organizations established in accordance with the laws of Vietnam, and individuals residing in Vietnam, when transferring investment projects or transferring capital, are responsible for fulfilling the tax obligations arising from the transfer of investment projects or capital in accordance with the provisions of tax law;

b) Organizations established under the provisions of foreign law, foreigners not residing in Vietnam transferring investment projects, transferring direct or indirect capital to organizations established under the provisions of Vietnamese law, or individuals residing in Vietnam, the transferee is responsible for determining, declaring, withholding, and paying on behalf of the transferor the tax payable. In the case where both the transferor and transferee are organizations established under foreign law, and foreigners do not reside in Vietnam, the organization established under Vietnamese law where the transferor directly or indirectly transfers capital is responsible for declaring and paying on behalf of the transferor the tax payable in accordance with tax law provisions.

7. The Government shall provide detailed regulations on this Article.

Section 4. TAX REFUND, OTHER REVENUES, LATE PAYMENT INTEREST, PENALTIES;

TAX EXEMPTION, OTHER REVENUE ITEMS; TAX REDUCTION, REVENUE ITEMS

OTHER; TAX-FREE; NOT SUBJECT TO TAX

Article 18. Tax refunds, other revenues, late payment interest, fines

1. Cases of tax refunds, other collections, late payment interest, fines:

a) Tax refund for organizations and individuals in cases of tax refund according to the provisions of tax law;

b) Refund taxes, other revenues, late payment fees, and overpaid fines to organizations and individuals in cases eligible for refund as prescribed in Article 15 of this Law;

c) Refunds to individuals in cases of tax refunds, other revenue, late payment fees, and penalties as stipulated in points a and b of this clause, if the individual has died, has been declared dead by a court, is missing, or has lost civil act capacity, shall be received by the heir or the person assigned by the court to manage the assets of the deceased, the person declared dead, missing, or with lost civil act capacity, according to the provisions of civil law.

2. Taxpayers who fall under the cases entitled to tax refunds, other collections, late payment interest, or fines as prescribed in Clause 1 of this Article (hereinafter referred to as tax refund) shall prepare and submit a tax refund dossier to the competent tax authority.

3. The tax authority shall classify tax refund dossiers or refund amounts to refund in advance to taxpayers or conduct inspections prior to the refund. The provision in this clause does not apply to the handling of overpaid taxes, late payment interest, or fines on exported or imported goods.

4. The tax authority shall implement automatic tax refunds based on data, risk management criteria, automated processing procedures, and information security assurance. The tax authority is responsible for implementing automatic tax refunds in stages, in accordance with actual conditions and conditions regarding infrastructure and information technology applications.

5. Authority to decide on tax refunds and the recovery of tax refunds:

a) The head of the tax administration agency decides on tax refunds, except for the cases specified in point b of this clause;

b) The tax authority decides on tax refunds for cases of automatic tax refund as prescribed in Clause 4 of this Article;

c) The head of the tax administration agency decides on the recovery of tax refunds for cases already refunded as prescribed in Clauses 1 and 4 of this Article.

6. The Government shall provide detailed regulations on Clause 1 of this Article and the following contents: cases of non-refund; cases of refunding in advance to taxpayers; cases of pre-refund inspection; time limit for receiving, processing, and responding to information on tax refund dossiers by the tax administration agency.

7. The Minister of Finance shall stipulate in detail the provisions of Clauses 2, 3, 4, and 5 of this Article and the following contents: procedures and formalities for tax refund; procedures and formalities for tax refund recovery; responsibility for receiving, resolving, and responding to information on tax refund dossiers of the tax administration authorities; offsetting debts through tax refunds.

Article 19. Tax exemption, other revenue; tax reduction, other revenue; non-collection of tax; non-subjection to tax

1. Cases of tax exemption, other revenue; tax reduction, other revenue; non-collection of tax; non-subjection to tax:

a) Tax exemption, other revenue; tax reduction, other revenue; non-collection of tax; non-subjection to tax for organizations and individuals in accordance with the provisions of tax law, fees and charges law;

b) Exemption from non-agricultural land use tax for households and individuals whose annual tax payable does not exceed the amount stipulated by the Government; exemption from personal income tax for individuals whose tax payable arises after the finalization of personal income tax from annual wages, salaries, and other types of taxes according to the amount regulated by the Government.

2. Taxpayers who fall under cases entitled to tax exemption, other revenue exemptions, tax reduction, or other reductions as prescribed in Clause 1 of this Article (hereinafter referred to as tax exemption or tax reduction) do not pay tax, are not subject to tax, and must prepare and submit dossiers to the competent tax authorities.

3. The tax authority implements automatic tax exemptions and reductions for taxpayers based on data, risk management criteria, automated processing procedures, and information security assurance. The tax authority is responsible for implementing automatic tax exemptions and reductions in stages, in accordance with practical conditions, infrastructure conditions, and information technology applications.

4. Authority to decide on tax exemption, tax reduction, non-collection of taxes, and tax non-liability:

a) The head of the tax administration agency shall decide on tax exemption, tax reduction, non-collection of taxes, and tax non-liability, except as provided in point b of this clause;

b) The tax authority shall decide on tax exemption and tax reduction for cases of automatic tax exemption and tax reduction as stipulated in clause 3 of this Article;

c) The head of the tax administration agency shall decide on the recovery of exempted taxes and recovered tax reduction amounts for cases of tax exemption and tax reduction as stipulated in clauses 1 and 3 of this Article.

5. The Government shall provide detailed regulations on clause 1 of this Article and the following contents: the time limit for receiving and processing dossiers for tax exemption, tax reduction, non-collection of taxes, and tax non-liability.

6. The Minister of Finance shall provide detailed regulations on clauses 2, 3, and 4 of this Article and the following contents: files for tax exemption, tax reduction, non-collection of tax, tax non-liability; responsibilities for receiving, handling, and responding to information on files for tax exemption, tax reduction, and non-collection of tax by tax authorities; procedures and processes for resolving tax exemption, tax reduction, non-collection of tax, and recovering tax-exempted money or tax-reduced money.

Section 5. WRITE-OFF OF TAX DEBTS, CANCELLATION OF TAX DEBTS

Article 20. Write-off of tax debts

1. Cases eligible for tax debt write-off:

a) Taxpayers who are deceased, persons declared by a court to be deceased, missing, or legally incapacitated.

b) The taxpayer who has made a decision to dissolve submits it to the business registration authority to carry out the dissolution procedures, the business registration authority has notified that the taxpayer is in the process of dissolution on the national business registration information system, but the taxpayer has not completed the dissolution procedures;

c) The taxpayer has been notified by the Court that the petition to apply bankruptcy procedures has been accepted or the tax debt has been suspended according to the court's written request in accordance with the laws on recovery and bankruptcy;

d) The taxpayer is no longer operating at the address registered with the business registration authority and the tax management authority;

d) Taxpayers whose business registration certificate, enterprise registration certificate, cooperative registration certificate, cooperative group registration certificate, business household registration certificate, establishment and operating license, professional practice license, branch operation registration certificate, representative office registration certificate, business location registration certificate, registration or license for e-commerce platform operation have been revoked by the competent authority;

e) Taxpayers who are practically restricted in the rights to exploit or use the granted or assigned land or minerals due to reasons from the competent state authority, resulting in debts of financial obligations related to land or minerals.

2. The head of the tax management agency decides on writing off tax debt amounts and terminating the validity of the decision on writing off tax debt amounts.

3. The tax authority monitors the amounts of tax debts that have been deferred and implements professional measures to urge the collection of tax debts.

4. Taxpayers are temporarily not subject to late payment interest during the period when the tax debts are deferred. After the decision to defer the tax debts ceases to be effective, the tax authority calculates the full amount of late payment interest from the time the tax payment deadline expires as prescribed, except in the case specified in point e, clause 1 of this Article.

5. The government shall detail this Article and the following contents: the time, the amount of tax debt to be deferred; cases of termination of the validity of the debt deferral decision; responsibilities of state agencies, methods, and criteria for determining cases specified in point e, clause 1 of this Article.

6. The Minister of Finance shall prescribe the procedures and dossiers for deferring tax debts.

Article 21. Cancellation of Tax Debts

1. Cases in which tax debts may be canceled:

a) Individuals who have died, individuals declared dead or legally incapacitated by the Court and who do not have assets, including inherited assets;

b) Enterprises, cooperatives, and cooperative unions declared bankrupt by the Court and that have carried out debt settlements according to provisions of the law on recovery and bankruptcy, and no longer have assets;

c) Taxpayers who are not subject to the cases specified in points a and b of this clause, but whose tax debts have been subjected to coercive measures by the tax authorities as prescribed in point h, clause 1, Article 49 of this Law, and the tax debt has exceeded 10 years from the due date but cannot be recovered;

d) Cases affected by natural disasters, calamities, or epidemics on a large scale that have been considered for exemption from late payment fines according to the provisions of clause 5, Article 16 of this Law, and have been granted extensions for tax payment, other revenue, late payment amounts, and fines under the provisions of point a, clause 7, Article 14 of this Law, but still cannot restore production and business activities and cannot pay the tax debt.

2. Taxpayers who are individuals, business individuals, household business owners, family household heads, owners of private enterprises, and single-member limited liability companies that have had their owed taxes written off as stipulated in point c, clause 1 of this Article before resuming production or business or establishing a new production or business facility must repay the State the amount of tax debt that has been written off.

3. The Chairman of the Provincial People's Committee shall report to the People's Council at the same level on the results of tax debt write-offs in the locality. The Ministry of Finance shall report to the Government on the results of tax debt write-offs to report to the National Assembly during the state budget finalization.

4. The Government shall provide detailed regulations for point d, clause 1 of this Article and the following contents: conditions for tax debt write-off; authority to write off tax debts; the deadline for resolving tax debt write-off dossiers; responsibilities for coordination of organizations and individuals in the recovery of tax debts that have been written off.

5. The Minister of Finance shall regulate the dossiers, order, and procedures for writing off tax debts and in the cases specified at points a, b, c of clause 1 and clause 2 of this Article.

Section 6. TAX INSPECTION

Article 22. Tax Inspection

1. Principles of tax inspection:

a) Apply risk management and information technology in tax inspection; prioritize online and remote inspections using electronic data;

b) Comply with legal regulations and not hinder the normal activities of taxpayers;

c) Tax inspection aims to assess the completeness, accuracy, and truthfulness of tax declaration and payment, as well as taxpayers' compliance with tax laws;

d) Tax inspection by tax authorities shall not overlap in content, scope, and time with inspections conducted by inspection agencies, the State Audit, except in cases where there is evidence or basis of violations that need to be re-inspected;

d) Check the determination of the taxpayer's related-party transaction prices according to the arm's length principle and the economic substance of the activities, with transactions generating corresponding tax obligations in line with the value created from the economic substance of the taxpayer's business activities and transactions; related-party transactions that do not follow the arm's length principle and reduce the company's tax obligations will not be recognized.

2. Tax inspection at the premises of the tax authority:

a) Tax inspection at the premises of the tax authority is conducted based on tax records and tax management databases available in the Tax Management Information System; the customs authority inspects the actual export and import goods when necessary and conditions are sufficient;

b) The tax management agency has the right to request taxpayers to explain, supplement information and documents; issue tax assessment decisions, handle administrative violations regarding tax management, or transfer to inspection at the taxpayer's premises;

c) Cases of post-clearance inspection are carried out in accordance with the provisions of customs law.

3. Tax inspection at the taxpayer's premises:

a) The tax authority conducts tax inspection in the following cases: cases where the file is subject to pre-refund inspection; cases where the file is subject to post-refund inspection for files eligible for pre-refund according to the principle of risk management in tax administration and within 5 years from the date the refund decision is issued; cases where there are signs of legal violations in the field of taxation; cases selected according to a plan or thematic topic; cases upon the request or proposal of agencies or competent persons; taxpayers with high risk in cases of: division, separation, merger, consolidation, conversion of business type, bankruptcy, dissolution, cessation of operation, equitization, termination of tax code validity, relocation of business address; cases prescribed in point b, clause 2 of this Article; cases of inspection upon request for resolution of tax complaints and denunciations; cases of tax exemption, tax reduction, or non-collection of tax for taxpayers with high risk;

b) The customs authority inspects taxes at the taxpayer's premises in the cases prescribed in point a of this clause; post-clearance inspections are carried out in accordance with the provisions of customs law; inspection of conditions for applying tax policies in accordance with the relevant laws.

During the inspection process, the customs authority conducts actual inspections of exported and imported goods when necessary and if the conditions still allow;

c) For cases selected according to the plan, specialized topics, and cases of division, separation, merger, consolidation, transformation of business types, bankruptcy, dissolution, termination of operations, equitization, termination of tax code validity, or relocation of business, the tax authority shall conduct inspections at the taxpayer's headquarters no more than once per year. This regulation does not apply to re-inspection cases as stipulated in point a, clause 6 of this Article;

d) The tax inspection period shall not exceed 20 days from the date of announcement of the inspection decision. If necessary, it may be extended once, but not more than 20 days. The tax inspection period for enterprises with related-party transactions shall not exceed 40 days, and if necessary, it may be extended once, but not more than 40 days. In case it is necessary to collect or exchange information with foreign tax authorities, the tax inspection period may be extended but not exceeding 2 years.

The inspection period specified in this point does not include the time of suspension of inspection according to the notice of the tax management authority.

4. Rights and obligations of taxpayers in tax inspection:

a) The rights of taxpayers in tax inspection shall be exercised in accordance with the provisions at point e and point r, clause 1, Article 37 of this Law and the provisions of the law on specialized inspections;

b) The obligations of taxpayers in tax audits are carried out in accordance with the provisions at point p, clause 2, Article 37 of this Law and the regulations of the law on specialized inspections.

5. Duties and powers of tax authorities in tax audits:

a) Heads of tax management agencies at all levels have the following duties and powers: issuing inspection decisions; adjusting inspection decisions; abolishing inspection decisions; directing inspection teams to comply with the content and deadlines stated in the tax inspection decision; applying measures stipulated in Article 23 of this Law; temporarily suspending, postponing, or extending the inspection period; making decisions on handling administrative violations in tax management under their authority or based on inspection conclusions or inspection result notifications, or recommending that competent authorities make conclusions and issue decisions on handling administrative violations in tax management; transfer the file to the inspection agency to conduct an inspection for complex cases with a wide scope, or transfer the audit file to the investigative agency in accordance with the law in cases where tax audits reveal violations in the tax field with signs of tax evasion or tax fraud to the extent that criminal liability must be pursued; handle complaints and denunciations within the authority;

b) The head of the inspection team has the following duties and powers: organize and direct the members of the inspection team to properly implement the content of the inspection decision; request taxpayers to provide information, documents, and explanations regarding issues related to the content of the tax inspection; apply measures prescribed in Clause 2, Article 23 of this Law; decide on sealing documents and goods (if any) of the subject being inspected when there is a basis to believe that there is a violation of the law in the field of taxation; prepare tax inspection minutes, and tax inspection minutes that clearly identify administrative violations shall be considered as administrative violation minutes; report to the person who issued the inspection decision on the inspection results;

c) Members of the inspection team, when carrying out a tax audit, have the following duties and powers: perform tasks as assigned by the head of the tax inspection team; require the taxpayer to provide information, documents, and explanations related to the issues of the tax audit assigned by the head of the team; report the results of the assigned tasks to the head of the tax inspection team.

6. Re-inspection in tax audit activities:

a) Cases of re-inspection:

The tax authority conducts re-examination of cases that have already been concluded and decisions on handling administrative violations in tax management in the following cases: issuance of an inspection decision beyond authority; violations of procedures and processes during the inspection leading to deviations in the content of inspection conclusions and decisions on handling administrative violations in tax management; errors in the application of law when handling administrative violations in tax management or inspection conclusions; the content of conclusions and handling of administrative violations in tax management is inconsistent with the evidence collected during the inspection; the decision-maker, head of the inspection team, or team members intentionally falsify case files or intentionally make conclusions and handle administrative violations in tax management illegally. There are signs of serious legal violations in the field of taxation by the taxpayer within the scope of the tax inspection decision that have not been fully detected through tax inspection.

The customs authority conducts a re-inspection for cases showing signs of tax law violations by taxpayers within the scope of tax inspection decisions but have not yet been inspected, detected, concluded, or have been concluded but not fully and accurately;

b) Authority to re-inspect: the higher-level tax management authority carries out the re-inspection of the case from the lower-level tax management authority;

c) The time limit for re-inspection is carried out according to the provisions at point d, clause 3 of this Article;

d) The statute of limitations for re-inspection is 02 years from the date of signing the inspection conclusion or decision on handling administrative violations regarding tax management;

dd) When conducting a re-inspection, the person who makes the inspection decision, the head of the inspection team, and the members of the inspection team perform their duties and powers according to the provisions of clause 5 of this Article.

7. The Minister of Finance shall provide detailed regulations on this Article.

Article 23. Measures applied during tax inspection in cases with signs of tax evasion

1. Collecting information related to cases with signs of tax evasion:

a) The head of the tax administration agency has the right to request agencies, organizations, and individuals related to cases with signs of tax evasion to provide information in writing or respond directly. The tax authority has the right to access accounting software data, electronic invoices, and cash registers of taxpayers showing signs of tax evasion;

b) Agencies, organizations, and individuals requested to provide information under point a of this clause are responsible for providing information correctly on the requested content, time, and address, and are accountable for the accuracy and truthfulness of the information provided.

2. Temporarily seizing documents related to cases with signs of tax evasion:

a) The head of the tax management agency, the head of the tax inspection team decides to temporarily seize documents related to cases with signs of tax evasion;

b) The temporary seizure of documents related to cases with signs of tax evasion is applied when it is necessary to serve as a basis for determining the act of tax evasion;

c) When temporarily seizing documents related to cases with signs of tax evasion, the head of the tax inspection team must make a temporary seizure record and is responsible for preserving the seized documents;

d) The tax management agency must deliver one copy of the temporary seizure decision and the temporary seizure record related to the case with signs of tax evasion to the organization or individual whose documents are temporarily seized.

Section 7. TAX ASSESSMENT

Article 24. Tax Assessment

1. Principles of tax assessment:

a) Tax assessment must be based on tax management principles, the tax base, and the method of calculating tax as prescribed by tax laws and customs laws;

b) The tax authority assesses the amount of tax payable or determines each element, the tax base, to ascertain the amount of tax payable.

2. Cases of tax assessment by the tax authority:

a) Failure to register for tax; failure to file taxes; failure to submit additional tax documents as requested by the tax authority, or filing taxes that are not complete, truthful, and accurate regarding the tax base;

b) Tax declarations have been submitted but it is not possible to determine the elements for establishing the tax base, or the elements for establishing the tax base are identified but the taxpayer cannot calculate the amount of tax payable;

c) Not reflecting or not fully, truthfully, and accurately reflecting the data in accounting books to determine tax obligations;

d) Failing to present accounting books, invoices, documents, and necessary materials related to determining the payable tax amount within the prescribed time;

d) Not complying with tax inspection decisions as prescribed;

e) Buying, selling, exchanging, and accounting for or declaring taxes based on the value of goods and services that does not match the actual payment or not according to the normal market transaction value, thereby reducing tax obligations;

g) Buying and exchanging goods using illegal invoices or documents, illegally using invoices or documents where the goods or services actually exist as determined by the competent authority and have been declared as taxable revenue;

h) Using documents or materials that do not accurately reflect the nature of the transaction or actual transaction value to reduce tax obligations. Conducting transactions not in accordance with economic reality for the purpose of reducing tax obligations;

i) Failure to comply with regulations on the obligation to declare, determine the transaction price of related-party transactions, or failure to provide information as stipulated by tax management law for enterprises arising from related-party transactions.

3. The Government regulates the following contents: basis for tax assessment; method of tax assessment; authority and procedures for tax assessment; responsibilities of taxpayers, tax declarants, and tax authorities in tax assessment.

Article 25. Tax assessment for exported and imported goods

1. Cases of tax assessment by customs authorities for exported and imported goods:

a) Taxpayers base their tax declaration and calculation on illegal documents, papers, or data; fail to declare tax or declare inaccurately, incompletely, or dishonestly in content related to determining tax obligations;

b) Beyond the time limit prescribed by customs law, other relevant legal regulations, or a written request from the customs authority when the taxpayer does not provide, refuses, or delays, prolonging the provision of dossiers, accounting books, documents, vouchers, data, figures related to accurately determining the amount of tax payable, exempted, reduced, refunded, not collected, or not subject to tax as prescribed;

c) The taxpayer does not provide evidence, explanation, or, beyond the prescribed time limit, fails to explain matters related to determining tax obligations according to the provisions of the law;

d) The taxpayer does not record or records incompletely, dishonestly, or inaccurately the data in accounting books, dossiers, documents, data, or accounting materials to determine tax obligations;

d) The customs authority has sufficient evidence and grounds to determine that the declaration of value, code, or origin of goods is not consistent with reality, affecting the amount of tax payable or incentives;

e) Transactions are conducted not according to their economic nature or not in accordance with actual occurrences, affecting the amount of tax payable, exempted, reduced, refunded, not collected, or not subject to tax;

g) The taxpayer cannot calculate the amount of tax payable themselves;

h) The taxpayer does not comply with the inspection decision of the customs authority;

i) Other cases detected by the customs authority or other authorities where the declaration or tax calculation does not comply with legal regulations.

2. Customs authorities determine the amount of tax payable based on the following grounds: actual exported and imported goods; tax base, tax calculation method; tax management database and trade database; customs dossiers; documents, books, vouchers, accounting data, results of inspection and examination, conclusions of competent authorities, or judgments and decisions of courts that have legal effect, and other information related to exported and imported goods.

3. The Government shall stipulate in detail Clause 1 and Clause 2 of this Article and the following contents: tax determination methods; authority and procedures for tax determination; responsibilities of taxpayers, tax declarants, and customs authorities in tax determination.

Chapter III. ELECTRONIC INVOICES, ELECTRONIC DOCUMENTS

Article 26. Electronic invoice

1. An electronic invoice is an invoice in electronic data form issued by organizations, business households, or individual businesses selling goods or providing services to record information on the sale of goods or provision of services in accordance with tax law and accounting law.

2. Electronic invoices include electronic invoices with codes from the tax authority, electronic invoices without codes from the tax authority, and electronic invoices generated from cash registers connected to the tax authority's data system.

3. Subjects using electronic invoices:

a) Taxpayers use electronic invoices with codes from the tax authority, electronic invoices without codes from the tax authority, and electronic invoices generated from cash registers connected to the tax authority's data system as prescribed by the Government;

b) Business households and individual businesses that are not required to use electronic invoices under government regulations, as well as enterprises, economic organizations, and organizations that need to use electronic invoices, must declare and pay taxes before being granted electronic invoices with a code by the tax authority for each transaction of selling goods or providing services.

4. Electronic invoice services include services that provide solutions for creating, transmitting, and storing electronic invoices with or without codes, and electronic invoices generated from cash registers connected to tax authorities' data. Organizations providing electronic invoice services must meet technical and personnel conditions, ensure information security and data confidentiality according to the regulations of the Minister of Finance, and are responsible for coordinating with tax authorities in exchanging and providing information for tax management purposes.

5. Principles, rights, and responsibilities in creating, managing, and using electronic invoices:

a) Organizations, business households, and business individuals must issue electronic invoices when selling goods or providing services to deliver to the buyer in the standard data format and must fully record the contents according to the provisions of tax law and accounting law, ensuring a complete and truthful reflection of the arising economic transactions and are responsible before the law for the accuracy of the issued invoices, except in cases where electronic invoices are not required according to government regulations;

b) The registration, management, and use of electronic invoices must comply with the provisions of the law on electronic transactions, accounting law, and tax law;

c) The timing of issuing electronic invoices is carried out according to government regulations;

d) Taxpayers are responsible for deploying technical infrastructure systems that meet the requirements for connection, storage, security, and retrieval of electronic invoices in accordance with the standard format and legal regulations;

d) Electronic invoice data is centrally and uniformly managed to build a database on invoices; it is connected and shared with relevant agencies and organizations to serve state management activities and protect the rights of buyers.

The tax authorities are responsible for organizing, building, managing, and operating the electronic invoice data system. Based on the results of risk analysis, the tax authorities apply appropriate management measures, including suspending or temporarily suspending the use of electronic invoices for cases with high tax and invoice risks;

e) Organizations providing electronic invoice services are responsible for establishing mechanisms to inspect, detect, and warn in the use of electronic invoices and provide information to the tax authorities;

g) The buyer has the right and responsibility to request the seller to provide an electronic invoice when purchasing goods and services; and is entitled to incentive measures in accordance with the law.

6. The government regulates the following contents: types of electronic invoices; subjects of use; content and timing of issuing electronic invoices; cases where electronic invoices are not required to be used; cases where the use of electronic invoices is exempt from service fees; duties, powers, and responsibilities of organizations and individuals in the management and use of electronic invoices.

7. The Minister of Finance shall stipulate the following contents: registration for using electronic invoices; electronic invoice formats; delegation of electronic invoice issuance; handling of issued electronic invoices; reference invoice template symbols, signs and samples; conversion to apply electronic invoices; criteria to identify taxpayers at high risk in registering to use electronic invoices; cases of suspension or temporary suspension of electronic invoice use; measures to encourage buyers to obtain invoices when purchasing goods and services and to reward consumers who report sellers not issuing and delivering electronic invoices from funds ensured by the state budget in the annual regular expenditure estimate as prescribed by law.

Article 27. Electronic documents

1. Electronic documents are documents for collecting taxes, fees, charges, or tax deduction documents in electronic data form issued to taxpayers by the tax administration agency or the organization responsible for tax deduction through electronic means.

2. Principles for the creation, management, and use of electronic documents:

a) The registration, management, and use of electronic vouchers must comply with the provisions of the law on electronic transactions, the law on accounting, and the law on taxation;

b) Organizations that create electronic vouchers must fully and truthfully reflect the transactions that arise and are legally responsible for the accuracy of the vouchers created.

3. Services related to electronic vouchers include services that provide solutions for creating, transmitting, and storing electronic vouchers. Service-providing organizations must meet technical requirements to ensure data security and confidentiality in accordance with the regulations of the Minister of Finance.

4. The government shall specify in detail the following contents: types of electronic vouchers; the contents and timing of issuing electronic vouchers; methods of issuing electronic vouchers, electronic tax administrative documents; connection and transmission of electronic voucher data; cases where the use of services is free of charge; tasks, powers, and responsibilities of organizations and individuals in the management and use of electronic vouchers.

5. The Minister of Finance shall specify in detail the following contents: registration for using electronic vouchers; electronic voucher formats; processing of issued electronic vouchers; sample symbols, electronic voucher symbols, and sample electronic vouchers for reference.

Chapter IV. INTERNATIONAL TAX COOPERATION AND INTERNATIONAL TAX MANAGEMENT

Article 28. Scope of international cooperation on taxes and international tax management

1. Signing and participating in international treaties, international agreements, international forums on taxation and other international organizations.

2. Implement international treaties and international agreements on taxation to which the Socialist Republic of Vietnam is a member or signatory, serving tax administration purposes.

3. Fulfill membership obligations under international treaties and international agreements to which the Socialist Republic of Vietnam is a member or signatory, as well as international tax forums serving tax administration purposes.

Article 29. Principles of international cooperation in taxation and international tax administration

1. Respect national sovereignty, equality, and mutual benefit.

2. Comply with international treaties and international agreements on taxation to which the Socialist Republic of Vietnam is a member or signatory.

3. Ensure the confidentiality of information and the legitimate rights of taxpayers in accordance with the laws of Vietnam and international treaties, international agreements to which the Socialist Republic of Vietnam is a member or a signatory, and international commitments regarding taxation.

Article 30. Content of international tax management by the tax administration authority

1. Subjects of international tax management are organizations and individuals within the scope of application of international treaties, international agreements on taxation to which the Socialist Republic of Vietnam is a member or a signatory.

2. Duties of the tax administration authority in managing international taxation:

a) Advise and assist the Minister of Finance in proposing the agency or person authorized to sign and implement rights and obligations and ensure the interests of the Socialist Republic of Vietnam under international treaties;

b) Negotiate, sign, and implement international tax commitments to carry out Double Taxation Avoidance Agreements, including: the Mutual Agreement Procedure (MAP), and Advance Pricing Agreements (APA).

In which, MAP is a written agreement between the Vietnamese tax authority and the tax authority of a country or territory that has signed a Double Taxation Avoidance Agreement with Vietnam, aimed at resolving tax disputes for taxpayers to avoid being taxed twice on the same income or asset, or to address situations where a tax authority of a country does not tax according to the provisions of the Double Taxation Avoidance Agreement. APA is a written agreement between the tax authority and the taxpayer (unilateral APA), or between the Vietnamese tax authority, the taxpayer, and the tax authority of a country or territory that has signed a Double Taxation Avoidance Agreement with Vietnam (bilateral or multilateral APA). This agreement aims to predetermine the method of price determination in related-party transactions, in accordance with the arm's length principle to serve as a basis for determining the corporate income tax obligations of enterprises engaged in related-party transactions within a specific period;

c) Negotiate, sign, and implement international commitments on taxes for exported and imported goods;

d) Guide the implementation and handle dossiers applying double taxation avoidance agreements and other international tax treaties;

đ) Exploit and exchange information about taxpayers and cooperate in tax operations with foreign tax authorities according to international treaties and agreements on taxes to which the Socialist Republic of Vietnam is a member or signatory, as well as international tax forums, to serve tax administration;

e) Cooperate and provide other administrative assistance on taxes with foreign tax authorities and international organizations in accordance with the laws of Vietnam and international treaties and agreements on taxes to which the Socialist Republic of Vietnam is a member or signatory;

g) Implementing the regulations on the Global Minimum Tax, tax management for enterprises with related-party transactions, and other membership obligations to which the Socialist Republic of Vietnam is a member or a signatory;

h) Organizing the collection and verification of information from agencies, organizations, and taxpayers according to the information exchange standards of the global forum on transparency and exchange of information for tax purposes.

3. The Minister of Finance shall stipulate the content, processes, and procedures for signing and implementing international commitments specified in point b, clause 2 of this Article.

4. The Government shall provide detailed regulations on points e, g, and h, clause 2 of this Article.

Article 31. Principles for implementing MAP and APA

1. Any agreement reached to implement the MAP under the Double Taxation Avoidance Agreements that the Socialist Republic of Vietnam has signed and that are in effect shall be carried out in accordance with the provisions of that Double Taxation Avoidance Agreement.

2. The application of the APA mechanism shall be carried out on the basis of the taxpayer's request, the agreement between the tax authority and the taxpayer according to unilateral, bilateral, and multilateral agreements among the tax authority, the taxpayer, and foreign or relevant territorial tax authorities, as decided by the head of the tax authority in accordance with the provisions of the Minister of Finance.

3. The application of the APA mechanism must be based on taxpayer information, databases used in tax administration for enterprises with related-party transactions, including: commercial databases; tax administration databases; data information of enterprises publicly disclosed on the stock market, information and data disclosed on domestic and international commodity and service exchanges; information and data officially published or provided by ministries, sectors, and state agencies to the tax authorities as prescribed by law; information collected through international tax cooperation exchanged by tax authorities of countries and territories under agreements and arrangements on double taxation avoidance, tax administrative assistance, and multilateral information sharing mechanisms.

4. The APA takes effect from the tax period in which the APA is signed or from the year following the year of signing, based on the content agreed upon by the tax authority and the taxpayer in the agreement.

Chapter V. RISK MANAGEMENT, COMPLIANCE MANAGEMENT, APPLICATION OF TECHNOLOGY,

DATA AND DIGITAL TRANSFORMATION IN TAX ADMINISTRATION

Article 32. Principles of applying risk management, compliance, and digital transformation in tax administration

1. The tax authorities apply risk management and compliance management to:

a) Improve the efficiency of tax administration and optimize the resources of the tax authorities;

b) Create a transparent and fair business environment and encourage taxpayers to voluntarily comply with tax laws; protect the lawful rights and interests of taxpayers;

c) Prevent, detect, stop, and promptly handle acts of non-compliance with tax laws.

2. The application of risk management and compliance management must ensure the following principles:

a) Ensuring objectivity, transparency, compliance with the law, and non-discrimination;

b) Based on objective, comprehensive, and updated data analysis;

c) Applying management measures suitable to the characteristics, compliance levels, and risk levels of each group and each taxpayer;

d) Prioritizing the application of modern information technology and automation in collecting, processing data, assessing compliance levels, and classifying risk levels.

3. The tax administration authority implements digital transformation and automation of management tasks based on the application of science, technology, and big data.

4. Transactions between taxpayers and the tax administration authority are conducted electronically through the Tax Management Information System, except for certain special cases as regulated by the Government.

5. Agencies and organizations use electronic documents provided by the tax management agency and are not allowed to require taxpayers to present paper documents in cases where the data is already available in the shared database of state agencies.

6. The Government shall provide detailed regulations for Clause 4 of this Article.

Article 33. Risk management in tax administration

1. The tax authority applies risk management in the administration of tax registration, tax declaration, other receivables, tax payment, other receivables, tax debt, other receivables, tax refund, other receivables, tax inspection, management and use of invoices, documents, and other professional activities.

2. Customs authorities apply risk management to decide on tax inspections in the implementation of customs procedures and other operational activities related to export, import, and transit goods in accordance with the provisions of customs law.

3. Risk management in tax administration operations includes collecting and processing tax information; developing criteria and organizing the assessment and classification of risk levels in tax administration activities; organizing the implementation of appropriate tax management measures.

4. Tax authorities apply the Tax Management Information System to integrate and process data to serve the application of risk management and automation in tax administration operations.

5. The Minister of Finance shall specify the following contents: criteria for assessing and classifying risk levels and the application of risk management in tax administration operations.

Article 34. Compliance management in tax administration

1. Tax authorities carry out compliance management to allocate resources effectively, encourage voluntary compliance, and create a fair business environment, including:

a) Develop a system for evaluating and classifying the level of tax law compliance of taxpayers, while maintaining electronic records for each taxpayer, including information on: the frequency of tax law violations; the nature and severity of the violations; the level of cooperation with tax authorities in performing tax procedures, inspections, and complying with decisions on handling violations; and other information related to tax obligations;

b) Combining propaganda, support, and encouragement for taxpayers to voluntarily comply with inspection and supervision measures based on the assessment of compliance levels, risk levels, and the compliance behavior of taxpayers;

c) Apply a priority regime for taxpayers who comply well with tax laws, are ready to connect and share electronic data with the tax authorities, including data on accounting books, invoices, documents, and other documents related to tax obligations through the Tax Management Information System as prescribed by the Government.

The government stipulates in detail the conditions, scope, and forms of applying preferential regimes for taxpayers who comply with the law.

2. The customs authority shall organize the unified application of legal compliance management for taxpayers, including: the establishment and management of taxpayer records; development of criteria, indicators, and organization of the assessment of taxpayers' legal compliance; support and encouragement for taxpayers to improve compliance capacity; application of inspection, supervision, post-clearance audit, and other professional measures according to the taxpayers' level of legal compliance in accordance with the provisions of the law.

3. The Minister of Finance shall stipulate the criteria for assessing taxpayers' legal compliance and compliance management activities in tax administration.

Article 35. Tax management information system

1. The tax management information system is centralized and integrated; it provides complete online public services and digital services for taxpayers; ensures the collection, processing, storage, updating, and management of accurate, complete, and timely information and data. The entire process is recorded and the history is stored in the system.

2. The tax management database is built, developed, and operated on a digital data platform, connected and synchronized with the national database system, the databases of ministries, sectors, international cooperation organizations, and relevant organizations. The tax authorities have the right to collect, access, use, and purchase commercial databases available on the market in accordance with the provisions of the law.

3. The Minister of Finance shall stipulate technical standards and develop information technology infrastructure to serve the connection, information exchange, and data sharing with relevant parties in accordance with the law. Ministries, ministerial-level agencies, agencies under the Government, local authorities, and relevant units are responsible for developing and implementing information technology systems that meet the requirements of connection and information exchange through the national data integration and sharing platform in accordance with regulations and ensuring the accuracy, completeness, and timeliness of the provided data.

4. The tax administration agency uses the Tax Management Information System to issue documents, notifications, and administrative tax decisions automatically based on business processes, management criteria, and data in the system. The automatically issued documents, notifications, and administrative tax decisions are signed with the digital signature of the tax administration agency and have the same legal value as paper documents. The processing process is recorded, history is stored in the Tax Management Information System, and allows taxpayers to search for recommendations, provide feedback, and request clarification of related information.

Article 36. Ensuring information security and managing information technology risks

1. Implement information technology risk management in tax administration in accordance with the law.

2. Ministries, ministerial-level agencies, government agencies, local authorities, relevant units, and tax administration agencies are responsible for:

a) Ensure safety, cybersecurity, and the confidentiality of taxpayer information throughout the process of building, deploying, and operating the Tax Management Information System;

b) Implement information technology risk management in tax administration;

c) Ensure full rights and obligations of taxpayers in the event of technological incidents, without interrupting the fulfillment of taxpayers' tax obligations.

3. In the event of technical issues in the Tax Management Information System when taxpayers conduct electronic transactions, resulting in taxpayers being unable to fulfill their tax obligations within the prescribed deadlines, taxpayers shall not be subject to administrative penalties for tax management violations, no late payment interest shall be calculated, and the time for processing tax records by the tax authorities shall not be counted during the period of the incident.

4. The Government shall provide detailed regulations on this Article.

Chapter VI. RIGHTS, OBLIGATIONS; DUTIES, AUTHORITY OF PARTIES INVOLVED IN TAX ADMINISTRATION

Article 37. Rights and obligations of taxpayers

1. Taxpayers have the following rights:

a) To be assisted and guided in fulfilling tax obligations; to be provided with information and documents to perform tax obligations and exercise tax rights;

b) To access, view, print, and use electronic documents that the taxpayer has submitted to the Tax Management Information System in accordance with the provisions of this Law and the law on electronic transactions; to request the withholding organization to issue electronic withholding documents;

c) Sign contracts with tax agents and customs procedure agents to provide tax agency services and customs procedure agency services; be authorized to file and pay taxes on behalf according to the provisions of the laws on taxation, tax management, and customs;

d) Be entitled to priority treatment in accordance with the provisions of the laws on tax and customs management if all conditions for priority treatment as prescribed by law are met;

đ) Be allowed to check the status of tax obligations and receive notifications of tax debts via electronic transaction accounts provided by the tax management authorities;

e) Receive notifications, decisions, minutes, and conclusions related to the determination of tax obligations from competent authorities during inspections, audits, and examinations;

g) To be explained about tax calculation, other collections, tax assessments, content related to handling taxes and other collections; to reserve opinions, provide explanations; to know the deadline for tax refund processing, the amount of tax not refunded, and the legal basis for the amount of tax not refunded;

h) Not required to submit documents or materials, not required to provide information that is already available in the tax file held by the tax authority, except in cases of content changes or upon the request of the tax authority for tax inspection purposes;

i) To request confirmation of completion of tax obligations;

k) To have information kept confidential in accordance with the provisions of Article 7 of this Law;

l) To file complaints or lawsuits against administrative decisions or administrative acts concerning taxes related to the legal rights and interests of the taxpayer;

m) To denounce acts of law violations by tax management officials, organizations, or other individuals in accordance with the laws on denunciation;

Amended and supplemented provisions:

n) Be compensated for damages in accordance with the provisions of the law on the liability of the State for compensation if harmed illegally by tax management agencies or tax management officers;

o) Not be subject to administrative sanctions on tax and invoice management, and not incur late payment fees in cases where the taxpayer fulfills their tax and invoice obligations according to administrative documents or decisions of the tax authority or competent state agencies related to the determination of the taxpayer's tax and invoice obligations;

p) Be allowed to request the inspection of export and import goods related to tax obligations;

q) Be allowed to request review and adjustment of information if discrepancies are discovered on documents submitted to the state treasury or data provided by the tax authority;

r) When the tax authority conducts a tax inspection, taxpayers have the right to refuse inspection at the taxpayer's premises if there is no inspection decision at the taxpayer's premises from a competent authority; refuse inspection at the tax authority's premises if there is no notice requesting explanation or additional information or documents from the tax authority; refuse to provide information or documents unrelated to the inspection content or classified as state secrets, except in cases provided otherwise by law; provide explanations on issues related to the inspection content and reserve opinions; file complaints, initiate lawsuits, request compensation for damages according to the provisions of law; report illegal acts during the tax inspection process; and exercise other rights in accordance with the specialized inspection law.

2. Taxpayers have the following obligations:

a) Register for tax and use a tax identification number in accordance with regulations;

b) Accurately, honestly, and fully declare and submit tax dossiers on time; be responsible before the law for the accuracy, honesty, and completeness of tax dossiers and the documents provided to the tax authorities during the tax dossier processing;

c) Pay all taxes, other amounts, late payment fees, and fines fully and on time. In cases where the amount to be paid has been provided with a payment identifier by the tax authorities, the taxpayer shall pay according to the payment identifier;

d) Comply with accounting, statistical regimes, and the use of invoices and documents in accordance with regulations;

đ) Accurately, honestly, and fully record and recognize activities that incur tax obligations, tax deductions, and transactions subject to tax information declaration.

e) Prepare and deliver invoices and documents to the buyer according to the correct quantity, type, and actual payment value when selling goods or providing services as prescribed by law;

g) Provide accurate, complete, and timely information and documents related to the determination of tax obligations in either paper or electronic form; provide information to tax authorities to facilitate information exchange with foreign tax authorities under international treaties or agreements on taxation to which the Socialist Republic of Vietnam is a member or a signatory; explain tax calculation, other revenue items, tax declaration, other revenue items, payment of taxes, or other revenues upon the request of the tax authorities;

h) Comply with decisions, notifications, and requests from the tax authorities and tax officers in accordance with the law.

i) Responsible for fulfilling tax obligations and other levies as prescribed by law, including in cases where a legal representative or authorized representative on behalf of the taxpayer performs tax procedures or other levies incorrectly according to regulations;

k) Operate the technical infrastructure to conduct electronic transactions and connect tax obligation information with the tax authority;

l) Use tax-exempt goods and services or other levies not subject to tax as declared correctly; if the purpose changes, a new declaration must be made and tax, other levies, and any arising amounts must be paid in accordance with the law;

m) Taxpayers with related-party transactions must prepare, store, declare, and provide documents on related-party transactions and related parties of the taxpayer, including related parties abroad;

n) Taxpayers who are social enterprises are responsible for accurately, honestly, and fully declaring the revenues from cooperation, sponsorship, and economic contracts with foreign organizations or individuals used for social or environmental purposes in accordance with tax laws and related legislation;

o) Taxpayers must pay the taxes and other levies determined according to tax handling decisions or other levy decisions by the tax management authority. In case of disagreement with the amount of tax or other levies determined by the tax management authority, the taxpayer must still pay that tax or other levy, while having the right to request explanation from the tax management authority or to file a complaint or lawsuit regarding the tax determination. Taxpayers are responsible for providing documents and materials to support their complaints or lawsuits;

p) When the tax authority conducts a tax inspection, the taxpayer is obliged to comply with the tax inspection decision at the taxpayer's premises of the tax authority; comply with the notice requesting explanation, supplementary information, and documents from the tax authority; provide timely, complete, accurate, and truthful information and documents related to the tax inspection content; sign the tax inspection minutes within the time limit prescribed by law; comply with the conclusions and decisions on handling the results of the tax inspection.

3. The Minister of Finance shall provide detailed regulations on the procedures for reviewing, adjusting information, and confirming the completion of tax payment obligations upon the taxpayer's request.

Article 38. Duties and powers of the tax authority and tax officers

1. Duties of the tax authority and tax officers:

a) Organize the implementation of revenue management for types of taxes according to the provisions of tax law, late payment fees, money collected from administrative violation penalties enforced by the tax authorities according to the provisions of the law on handling administrative violations;

b) Organize the implementation of revenue management for other revenues including: fees and charges according to the provisions of the Law on Fees and Charges; land use fees; land lease fees; fees for the granting of mineral exploitation rights; fees for the granting of water resource exploitation rights; fees for the use of sea areas; revenue from the privatization of enterprises and public service units; revenue from capital transfer, transfer of purchase rights for shares, capital contribution rights of the state in enterprises; remaining after-tax profit after the allocation to funds as prescribed by enterprises wholly owned by the State, dividends and profits distributed for the State's capital portion in enterprises as prescribed; other revenues belonging to the state budget according to legal regulations.

For fees and charges not directly collected by the tax authorities, the agencies or organizations assigned to collect fees and charges in accordance with the Law on Fees and Charges shall carry out the management of collection as stipulated in Clause 7, Article 39 of this Law.

For revenues under the management of state agencies of other organizations but assigned to the tax authority for collection, the agency or organization managing the revenue is responsible for transferring information regarding the determination of financial obligations and obligations to pay to the state budget to the tax authority in charge of collection, and is responsible for the accuracy, completeness, and timeliness of the information on financial obligations and obligations to pay to the state budget in accordance with the law. In the case of any changes in information related to the determination of financial obligations or obligations to pay to the state budget that have been transferred to the tax authority, the agency or organization managing the revenue is responsible for notifying the tax authority to adjust and notify the amount of tax and other revenues, late payments, and fines payable by the taxpayer.

c) Propagate, disseminate, guide, and explain tax laws to taxpayers; publicly disclose tax administrative procedures, programs encouraging voluntary compliance, preferential regimes at headquarters, provincial and commune-level public administrative service centers, on the Tax Management Information System, and in mass media; apply digital technology to improve the effectiveness of assisting taxpayers in declaration, reporting, fulfilling tax obligations, and enhancing compliance with tax laws;

d) Provide and share taxpayer information to serve tax management according to regulations;

d) Confirm the fulfillment of tax obligations and handle verification and adjustment of information according to the procedures and processes prescribed by law. Confirm the completion of transactions in cases where taxpayers complete transactions electronically;

e) Provide information on the fulfillment of tax obligations of taxpayers (including the amount of tax, other overpaid amounts), and notify the amount of tax debt through the taxpayer's electronic transaction account;

Amended and supplemented provisions:

g) Compensate damages to taxpayers in accordance with the law on state liability for compensation in cases of unlawful damage;

h) Conduct tax assessment at the request of competent state agencies to determine the tax obligations to be paid;

i) Develop and operate electronic information systems, apply information technology and digital transformation in tax management; ensure data security, and establish interconnected connections with the systems of relevant state agencies;

k) Implement accounting for tax payments, other revenues, late payments, fines receivable by the tax authorities, collected amounts, exemptions, reductions, debt write-offs, and refunds in accordance with the provisions of accounting law and state budget law;

l) Organize the implementation of tax statistics work in accordance with the provisions of the law;

m) Manage taxes on cross-border transactions, the digital economy, e-commerce, digital assets, and newly arising economic types and transactions;

n) Tax administration officials have the duty and are responsible for handling tax records within the scope of the documents, materials, and information provided by taxpayers, the tax management database, information provided by competent state agencies related to the taxpayer, the results of risk management application in tax administration, ensuring compliance with their functions and duties, adhering to tax law, tax management, and other relevant legal regulations, and are not responsible for the contents in documents, papers, or materials in the tax file that have been approved, evaluated, ratified, or resolved previously by other authorities or competent persons;

o) Tax authorities are responsible for assisting taxpayers in cases where taxpayers encounter difficulties in performing tax procedures.

2. Powers of the tax authority:

a) Require taxpayers to provide information and documents related to tax obligations, including investment information, owners, bank accounts, financial information, and explanations concerning tax declaration, calculation, payment, other collected amounts; require related organizations and individuals to provide information and documents serving tax administration, exchange information with foreign tax authorities under international treaties or agreements on taxation, and coordinate in fulfilling tax obligations; purchase and use information and data domestically and internationally to serve tax administration; use information from national databases and specialized databases to carry out tax administration and resolve administrative procedures;

b) Conduct tax inspections; determine taxes according to regulations; enforce administrative decisions on tax; impose administrative penalties and publicly announce cases of violations in the media; apply measures to prevent and ensure the handling of violations in accordance with the law, including requiring the suspension of business, requesting the business registration authority to temporarily halt changes to business, cooperative, cooperative union, cooperative group, or household business registrations while handling tax violations; authorize tax collection to organizations and individuals as prescribed by the Minister of Finance.

3. The Government shall provide detailed regulations for Clause 1 of this Article.

Article 39. Duties, responsibilities, and powers of state agencies, inspection and supervision agencies, the Vietnam Fatherland Front, political - professional organizations, social organizations, and socio-professional organizations in tax management

1. The Government has the following duties and powers:

a) Unify state management on tax administration, ensuring close coordination between sectoral management agencies and local authorities in tax management;

b) Extend deadlines for paying taxes, other revenues, late payment fees, and fines for entities and industries engaged in production and business in cases of particular difficulties during certain periods;

c) Report to the National Assembly, the Standing Committee of the National Assembly, and the President on tax management as required.

2. The Ministry of Finance is responsible for assisting the Government in unifying state management on taxes and other revenues belonging to the state budget.

3. Ministries, ministerial-level agencies, and government-affiliated agencies, within the scope of their state management, have the following responsibilities:

a) Coordinate with the Ministry of Finance in implementing tax policies, managing taxes, carrying out digital transformation, sharing information and data to prevent tax evasion, tax fraud, and budget loss in business activities on digital platforms, e-commerce, cross-border services, new business models, and other business sectors;

b) Connect and share information for tax management with tax authorities electronically.

4. People's Councils at all levels, within the scope of their tasks and powers, decide on the annual budget revenue tasks and supervise the implementation of tax laws locally.

5. People's Committees at all levels, within the scope of their tasks and powers, have the following duties:

a) Direct the relevant local agencies to coordinate with the tax administration agency to prepare budgets and organize the implementation of tax collection tasks and other revenue items belonging to the state budget in the area; carry out asset inventory, auction of assets for taxpayers who are subject to enforced execution of administrative decisions on tax management through asset inventory and auction measures;

b) Coordinate with the Ministry of Finance, tax management agencies, and other competent agencies in managing and implementing tax law;

c) Handle administrative violations and resolve complaints and denunciations related to the implementation of tax law within their authority;

d) Perform the state management function over fees, charges, and other state budget revenues not managed by tax authorities, under the authority of People's Committees at all levels.

6. State agencies and organizations assigned to manage the collection of other state budget revenues shall organize the collection into the state budget in accordance with the provisions of specialized laws and shall apply the regulations on calculating late payment interest, handling overpaid amounts in accordance with this Law, and recommend to competent state agencies to implement coercive measures stipulated in points c, d, h of Clause 1, Article 49 of this Law, including:

a) Money collected from administrative penalty sanctions shall be handled by state agencies and organizations assigned to manage collection in accordance with the law on handling administrative violations;

b) Money paid to the state budget in accordance with the provisions of the law on the management and use of public assets from the management, use, and exploitation of public assets for business purposes, leasing, joint ventures, cooperation, and disposal of public assets after fulfilling tax, fee, and charge obligations;

c) Fees for the right to use radio frequencies;

d) Aid letters;

dd) Late payment fees for revenues under this item;

e) Other revenues as prescribed by law.

7. State agencies or organizations assigned to collect fees and charges shall organize the collection into the state budget in accordance with the provisions of the Law on Fees and Charges; they shall apply the provisions on calculating late payment, handling excess payments according to this Law, and propose that competent state agencies implement compulsory measures specified in points c, d, h, Clause 1, Article 49 of this Law.

8. State agencies are responsible for providing taxpayer information to tax authorities through electronic means:

a) Agencies that issue various types of certificates and licenses are responsible for providing information on the content of investment registration certificates, business registration certificates, cooperative registration certificates, cooperative group registration certificates, household business registration certificates, information on owners, professional practice licenses, establishment and operation licenses, certificates of changes in business registration information of organizations and individuals, and providing other information as requested by the tax management agency;

b) The State Treasury provides information on the amount of taxes, other revenues, late payment fees, and fines that have been paid or refunded by taxpayers;

c) State management agencies for housing and land provide information on the current land use status and house ownership of organizations, households, household businesses, and individual businesses;

d) Law enforcement agencies provide and exchange information when detecting that a taxpayer has committed acts with signs of crime in the field of taxes; provide information on exit, entry, and information on registration and management of the taxpayer's vehicles;

d) State management agencies in the field of commerce provide information on the management policies for exported, imported, and transit goods of Vietnam and foreign countries; information on market management;

e) Courts provide and exchange information regarding the resolution of rehabilitation, bankruptcy, persons declared by the Court or whose declaration decisions have been annulled as deceased, missing, or legally incapacitated, and information on inheritance according to civil law;

g) State agencies shall provide full, timely, and accurate information as requested by the tax authorities to implement international agreements or treaties on taxation to which the Socialist Republic of Vietnam is a member or a signatory.

9. Duties and powers of the State Audit:

a) Conduct audits of the activities of tax management agencies in accordance with the provisions of the law on state audit, tax law, and other relevant legal regulations;

b) In cases where the State Audit directly audits taxpayers in accordance with the provisions of the State Audit Law, and there are recommendations regarding the tax obligations and other amounts payable to the state budget of the taxpayer, the State Audit is responsible for identifying violations in the field of tax management by the taxpayer and sending the audit minutes or report to the taxpayer. The taxpayer is responsible for implementing the recommendations according to the State Audit's minutes or report. The tax authority, based on the taxpayer’s administrative violations in the document prepared by the State Audit and sent to the tax authority, shall proceed to handle administrative sanctions in tax management in accordance with the provisions of the Law on Handling Administrative Violations and this Law. In cases where the taxpayer disagrees with the State Audit's recommendations, the taxpayer has the right to file a complaint against the State Audit's recommendations;

c) In the case where the State Audit does not directly audit the taxpayer but conducts the audit at the tax administration agency regarding the recommendations stated in the audit report related to the tax obligations and other payments payable to the state budget by the taxpayer, the State Audit is responsible for determining the violations in the field of tax management committed by the taxpayer and sending copies of the documents containing recommendations related to the tax obligations and other payments payable to the taxpayer for implementation. The tax administration agency is responsible for organizing the implementation of the recommendations of the State Audit. In case the taxpayer does not agree with the tax obligations and other payments payable, the taxpayer shall submit a written request for the tax administration agency and the State Audit to reconsider the tax obligations and other payments payable. Based on the proposal of the taxpayer, the State Audit shall take the lead, coordinating with the tax management agency to accurately determine the tax obligations and other revenues of the taxpayer and shall be responsible in accordance with the provisions of the law.

10. Duties and powers of the inspection agency:

a) Conduct inspections of the activities of tax management agencies in accordance with the provisions of the law on inspection, tax law, and other relevant legal regulations;

b) In the case where the inspection agency directly inspects the taxpayer according to the provisions of the Law on Inspection and the content includes conclusions on the taxpayer's tax obligations and other amounts payable to the state budget, the inspection agency is responsible for determining the taxpayer's violations in the field of tax management and sending the minutes, conclusions, or post-inspection decisions to the taxpayer, and the taxpayer is obliged to implement the conclusions or post-inspection decisions of the inspection agency. The tax management agency, based on the administrative violation of the taxpayer in the document prepared by the inspection agency and sent to the tax management agency, shall proceed to handle administrative sanctions on tax management in accordance with the provisions of the Law on Handling Administrative Violations and this Law. In cases where the taxpayer does not agree with the conclusions or decisions for handling after inspection and the determination of violations in the field of tax administration by the inspection agency, the taxpayer has the right to file a complaint against the conclusions or decisions of the inspection agency;

c) In cases where the inspection agency does not directly inspect the taxpayer but conducts an inspection at the tax management agency regarding the content of recommendations stated in the inspection conclusion or post-inspection handling decision related to the taxpayer's tax obligations and other amounts payable to the state budget, the inspection agency is responsible for identifying violations in the field of tax management by the taxpayer and sending a copy of the conclusion or post-inspection handling decision related to tax obligations and other amounts payable to the taxpayer for implementation. The tax management agency is responsible for organizing the implementation of the conclusion or post-inspection handling decision of the inspection agency. In cases where the taxpayer disagrees with the tax obligations and other amounts payable, the taxpayer may submit a written request to the tax administration authority or the inspection agency to review the tax obligations and other amounts payable. Based on the taxpayer's request, the inspection agency shall take the lead, in coordination with the tax administration authority, in accurately determining the taxpayer's tax obligations and other amounts payable and shall be responsible in accordance with the provisions of the law.

11. Investigation agencies, the Procuracy, and the Courts, within the scope of their duties and powers, are responsible for receiving, handling, and resolving reports and denunciations of crimes, and for recommending prosecution, initiating prosecution, investigating, prosecuting, and promptly and rigorously adjudicating crimes in the field of taxation in accordance with the law, and for notifying the results of handling to the tax management agency.

12. Duties and powers of competent state agencies in inspecting and supervising the implementation of laws on taxes, fees, and charges:

a) Conduct inspections and supervise the implementation of laws on taxes, fees, and charges in relation to tax management agencies at all levels and organizations collecting fees and charges in accordance with the provisions of specialized inspection law;

b) Organize inspections and supervision according to periodic or ad-hoc plans, overall or thematic, at the headquarters of the inspecting agency or at the unit being inspected or supervised;

c) Issue written inspection decisions, prepare inspection minutes, and comply with the order and procedures according to the provisions of specialized inspection law;

d) Request the unit being inspected, supervised, and relevant agencies, organizations, or individuals to explain and provide complete and timely documents and materials for inspection and supervision work, and be legally responsible for the accuracy and truthfulness of the information provided.

13. Duties and powers of the Vietnam Fatherland Front:

a) Propagate and mobilize the people to strictly comply with tax laws;

b) Conduct social supervision and critique regarding taxes; report and submit recommendations to state agencies to consider and resolve tax-related issues in accordance with the law.

14. Socio-political and professional organizations, social organizations, and social-professional organizations have the task of coordinating with tax management agencies in propagating, disseminating, and educating tax law to their members and providing information related to tax management.

15. The Government shall provide detailed regulations on this Article and the following contents: the content, form, scope, and time limits for providing information, responsibilities, and powers of the relevant parties in sharing and connecting information to serve tax management.

Article 40. Duties, responsibilities, and powers of other organizations and individuals in tax management

1. Information and press agencies have the following duties and powers:

a) Propagate and disseminate tax policies and laws, highlight organizations and individuals that comply well with tax laws, reflect on and criticize acts of violating tax laws;

b) Coordinate with tax management agencies in posting and providing information in accordance with the law.

2. Credit institutions, branches of foreign banks, organizations providing payment services, organizations providing intermediary payment services have the following duties and powers:

a) Coordinate with the tax authorities and the State Treasury in implementing electronic tax payment, other electronic receipts, and electronic tax refunds for taxpayers; process and reconcile data on electronic tax payments, other electronic receipts, and electronic tax refunds; transmit and receive electronic tax payment documents, transfer money to the budget, and send information to the tax authorities fully, accurately, and promptly in accordance with the law; do not cancel the money transfer order after the tax payment information has been sent to the tax authorities; assist taxpayers in the process of making electronic tax payments; keep the information of taxpayers and customs declarants confidential in accordance with the law;

b) Periodically provide information on the account number according to the taxpayer identification number when opening and closing a payment account at the payment service provider where the payment account was opened;

c) Implement connection and share information related to transactions and other information of taxpayers to serve tax management; provide information, unusual transactions, and provide complete, timely, and accurate information as requested by the tax authorities to implement international treaties or international agreements on tax to which the Socialist Republic of Vietnam is a member or a signatory as requested by the tax administration authorities;

d) Receive decisions on coercive measures by withdrawing money from the account, freezing the account of taxpayers against whom coercive execution of administrative decisions on tax management via electronic means is carried out; withdrawing money to pay taxes, other revenues from the account of taxpayers, freezing the account of taxpayers subject to coercive execution of administrative decisions on tax management at the request of the tax administration agency;

d) In the case where taxpayers have provided a guarantee for the taxes payable, late payment fees, fines, and other revenues belonging to the state budget in accordance with this Law but fail to pay on time, the guarantee organization must be responsible for paying in full the taxes, late payment fees, fines, and other revenues belonging to the state budget on behalf of the taxpayer within the scope of the guarantee agreed upon in the contract, agreement, commitment, and guarantee period;

e) Payment service providers (excluding the State Bank) provide information on imported goods pledged as collateral for loans upon the request of customs authorities;

g) In case the secured party (excluding the State Bank) sells the collateral to handle debt according to the provisions of the law on collateral handling and the law on credit institutions, the secured party or the buyer according to the agreement under civil law is responsible for declaring and fully paying all tax obligations related to the collateral handling transaction on behalf of the guarantor.

In case the sold collateral is imported goods that are subject to tax exemption or not subject to tax, the seller of the collateral or the buyer according to the agreement under civil law is responsible for declaring and fully paying all tax obligations related to the collateral on behalf of the guarantor.

h) Regarding tax amounts, other revenue that is late or insufficiently paid into the state budget due to the fault of the payment service provider or intermediary payment service provider causing the taxpayer to incur late payment fees, the payment service provider or intermediary payment service provider is responsible for paying the late payment fees to the taxpayer according to the provisions of this Law;

i) The intermediary payment service provider is responsible for coordinating with the tax administration agency in tax collection work.

3. Other organizations and individuals have the following duties, responsibilities, and powers:

a) Provide information related to the identification of taxpayers, tax obligations, and provide complete, timely, and accurate information as requested by the tax authorities to implement international treaties or international agreements on taxes to which the Socialist Republic of Vietnam is a member or a signatory, at the request of the tax authorities;

b) Cooperate with the tax authorities in implementing decisions on administrative penalties for tax management violations;

c) Report acts of tax law violations to the tax authorities or competent state agencies;

d) Require sellers or service providers to issue invoices and documents for goods and services accurately reflecting the quantity, type, and actual payment value when purchasing goods and services;

d) Authorized persons, guarantors, or those who pay taxes on behalf of taxpayers are responsible for providing information about exported and imported goods to the tax management authority as a basis for tax assessment in accordance with Article 25 of this Law;

e) Other agencies, organizations, and individuals related to taxpayers are responsible for cooperating and providing information to serve tax management work in paper or electronic form as requested by the tax management authority;

g) E-commerce platform management organizations, digital asset service providers, logistics service providers, international card organizations, foreign organizations providing payment services, intermediary payment services, or electronic transaction processing services to organizations and individuals in Vietnam are responsible for providing information periodically or upon request to the tax management authority;

h) Organizations and individuals that pay income must provide information on income payments and the amount of tax withheld from the taxpayer, the amount of tax, and other revenue items that have been declared on behalf of, or paid on behalf of, the taxpayer to the tax authorities as prescribed by the Government;

i) Third parties who have debts owed to them or hold money or other assets of the subject under coercion must provide information on the debts or the money or other assets held of the subject under coercion and are responsible for paying the owed taxes on behalf of the subject under coercion;

k) Agencies and organizations that collect auction sale proceeds are responsible for providing information about the name of the goods, quantity, and appraised value that have been seized and auctioned to the customs authorities in order to determine taxes on imported goods that have not completed customs procedures and are seized and auctioned by the customs authorities to enforce administrative decisions on tax management in the customs sector, goods that are tax-exempt, not subject to tax, seized and auctioned according to the decision of the competent authority, or according to court judgments and decisions that are subject to tax payment;

l) In the case that an auction organization carries out the sale of secured assets to settle the obligations of a taxpayer, if the ownership or usage rights of the assets have been transferred to the auction organization, the auction organization is responsible for declaring and paying taxes, late payment fees, fines, and other state budget revenues arising from the secured assets. If the secured assets still belong to the ownership or usage rights of the taxpayer, the auction organization is responsible for withholding and paying on behalf of the taxpayer the tax and other revenues related to the secured assets as prescribed. The auction organization is responsible for fully declaring and paying tax obligations related to secured assets that are imported goods subject to tax exemption, not subject to tax according to regulations, on behalf of the taxpayer.

4. In the case that the organizations specified in points a, b, c, d, đ, and e of clause 3 of this Article detect errors or omissions that need to be corrected regarding the information that has been exchanged or provided between agencies, they shall send a file for review and adjustment of the information according to regulations.

5. Tax agents, business households, and individuals engaged in business services for tax procedures:

a) A tax agent is an enterprise established and operating under the provisions of the law, having at least 02 persons who meet the standards for providing tax consulting services, working full-time at the enterprise, and performing tax procedure services according to agreements with taxpayers;

b) A business household or individual providing tax procedure services is an individual who meets the standards for providing tax consulting services and operates under the provisions of the law, performing tax procedure services according to agreements with taxpayers;

c) Services provided by tax agents, business households, or individuals providing tax procedure services to taxpayers under a contract include: procedures for tax registration, tax declaration, tax payment, tax finalization, preparing files for tax exemption, tax reduction, tax refund, and other tax procedures on behalf of taxpayers; tax consulting services; accounting services in accordance with the provisions of the law on accounting;

d) Tax agents, business households, and individuals providing services for tax procedures have the following rights and obligations: to comply with the provisions of this Law, tax laws, and other relevant legal regulations in the practice of providing services for tax procedures; to be legally responsible and responsible to taxpayers for the content of the services provided.

6. Customs procedure agents shall carry out procedures in accordance with the provisions of customs law.

7. The Minister of Finance regulates the management of business activities providing services for tax procedures.

8. The government shall specify in detail the following: the tasks and powers of information agencies, press agencies, and credit institutions, foreign bank branches, organizations providing payment services, organizations providing intermediary payment services, organizations providing online payment services, and the content, form, method, and time frame for providing information in sharing and connecting information for tax management as stipulated in this Article; business standards for tax procedure service providers.

Chapter VII. COMPLAINTS, DENUNCIATIONS, AND DISPUTE RESOLUTION

Article 41. Complaints, denunciations, and dispute resolution regarding taxes

1. Taxpayers, organizations, and individuals have the right to file complaints with the competent authority regarding administrative decisions and administrative acts of the tax management agency or the competent person of the tax management agency when there are grounds to believe that such decisions or acts are illegal and directly infringe upon their lawful rights and interests. Complainants are entitled to know the procedures and processes for resolving complaints through the Tax Management Information System as prescribed by law.

2. Individuals have the right to denunciation of legal violations regarding taxes by taxpayers, tax management officials, or other organizations and individuals.

3. The authority, procedures, and processes for handling complaints and denunciations are carried out according to the provisions of the law on complaints and denunciations.

4. Tax disputes with foreign elements between taxpayers who are foreign or Vietnamese organizations or individuals and the Vietnamese tax authorities, relating to tax obligations arising in Vietnam or abroad, may be resolved through:

a) The order and procedures for filing a complaint according to the regulations of the law on complaints;

b) The sequence and procedures of proceedings according to the provisions of the law on administrative procedures;

c) The dispute resolution mechanism stipulated in the contract, agreement, and government guarantee commitment, as well as in international tax treaties and other international treaties to which the Socialist Republic of Vietnam is a member or a signatory (if any).

Article 42. Responsibilities and powers of the tax administration agency in handling tax complaints

1. The tax administration agency receiving a complaint regarding the implementation of tax law has the right to request the complainant to provide files and documents related to the complaint; if the complainant refuses to provide files and documents, the agency has the right to refuse to consider the complaint.

2. The tax administration agency must refund incorrectly collected taxes, other fees, late payment charges, and penalties to the taxpayer or third party within 15 days from the date of receipt of the decision of the competent authority.

3. For complex complaint cases, the head of the tax administration agency resolving the complaint shall consult with relevant agencies and organizations, including for first-time complaints. When conducting consultations, the head of the tax administration agency must issue a decision to establish a Consultation Council. The Consultation Council operates on the principle of collectivity and votes by majority. The voting results serve as a reference for the head of the tax administration agency when making a decision on handling the complaint. The head of the tax administration agency is the person who issues the decision and is responsible for the decision on handling the complaint.

Article 43. Filing a Lawsuit

The filing of a lawsuit against administrative decisions or administrative actions of the tax administration agency, persons authorized by the tax administration agency, or state agencies shall be carried out according to the provisions of the law on administrative procedures.

Chapter VIII. HANDLING ADMINISTRATIVE VIOLATIONS IN TAX MANAGEMENT AND ENFORCING ADMINISTRATIVE DECISIONS ON TAX MANAGEMENT

Section 1. HANDLING ADMINISTRATIVE VIOLATIONS IN TAX MANAGEMENT

Article 44. Principles for sanctioning administrative violations in tax management

1. The sanctioning of administrative violations in tax management shall be carried out in accordance with the provisions of the law on tax management and the law on handling administrative violations.

2. Cases where administrative sanctions in tax management are not applied:

a) In cases where the taxpayer provides incorrect declarations as stipulated in Clause 2, Article 45 of this Law but has submitted a supplementary tax declaration and voluntarily paid the full amount of tax due before the tax authority announces a tax inspection decision, another competent authority announces an inspection decision at the taxpayer's premises, or before the tax authority detects the error without inspecting at the taxpayer's premises, or before the other competent authority detects it; individuals who directly finalize personal income tax late but have arising refundable tax amounts; and other cases not subject to administrative penalties as prescribed in this Law, other relevant legal regulations, and other cases as prescribed by the Government;

b) In cases where the taxpayer has acts of incorrect declaration as prescribed in Clause 3, Article 45 of this Law but has made a supplementary declaration before the customs authority notifies the direct inspection of the customs dossier for the goods undergoing customs procedures; the taxpayer makes a supplementary declaration within 60 days from the date of customs clearance and before the decision to inspect or examine the goods that have been cleared, post-clearance inspection, and other cases as prescribed by the Government.

3. The application of monetary penalties in administrative sanctions for tax management is carried out as follows:

a) A fine of 10% calculated on the amount of underreported tax payable or the amount of overreported tax in cases where exemption, reduction, refund, or no tax collection is applied for the act specified in point a, clause 3, Article 45 of this Law;

b) A fine of 20% calculated on the amount of underreported tax due or the overreported tax in cases of exemption, reduction, refund, or non-collection of tax for acts stipulated in Clause 2 and Points b and c, Clause 3, Article 45 of this Law;

c) A fine ranging from 1 to 3 times the evaded tax amount for acts stipulated in Clause 4, Article 45 of this Law.

4. For the same administrative violation in tax management, the monetary penalty for organizations is twice the amount of the penalty for individuals. Specifically, for acts of erroneous declaration leading to underpayment of tax or overreporting of tax exemption, reduction, refund, or non-collection, and acts of tax evasion, the monetary penalty does not differentiate between organizations and individuals.

5. In cases where the taxpayer is subject to tax assessment according to the provisions of Articles 24 and 25 of this Law, depending on the nature and severity of the violation, they may be subject to administrative sanctions for tax management violations in accordance with the provisions of this Law.

6. In cases where violations of tax management laws reach the level of criminal liability, they shall be handled in accordance with the provisions of criminal law.

7. For violations of tax procedures, the statute of limitations for penalties is 02 years. For acts of tax evasion that have not reached the level of criminal liability, acts of incorrect declaration leading to a shortfall in payable tax amounts or an increase in tax amounts exempted, reduced, refunded, or not collected, the statute of limitations for penalties is 05 years. The time point for calculating the statute of limitations for administrative sanctions is implemented according to the provisions of the law on handling administrative violations.

8. After the statute of limitations for administrative penalties for tax management violations has expired, the taxpayer will not be subject to penalties but must still pay in full the amount of unpaid tax, evaded tax, exempted, reduced, refunded, or incorrectly non-collected tax, as well as late payment interest to the state budget for up to 10 years prior from the date the violation is detected. In the case where the taxpayer has not registered for tax, they must pay in full the amount of unpaid tax, evaded tax, and late payment interest for the entire period prior from the date the violation is detected.

9. Taxpayers who are fined for administrative violations in tax administration but suffer losses in cases of force majeure as prescribed in Clause 21, Article 4 of this Law shall be exempted from fines. The total amount of fine exemption shall not exceed the value of the damaged assets or goods. No fine exemption for administrative violations in tax management shall be applied to cases where administrative penalty decisions on tax administration have already been enforced by the tax authorities or competent state agencies.

10. The Government shall provide detailed regulations on this Article.

Article 45. Violations in the field of tax administration

1. Violations of tax procedures, invoices, and electronic documents.

2. Acts of incorrectly declaring the tax calculation basis or incorrectly determining cases eligible for tax exemption, reduction, refund, or using invoices and documents that are not legal, which are not the fault of the buyer, leading to a shortage of tax payable or an increase in tax exempted, reduced, or refunded, but these economic transactions have been fully recorded and reflected in the accounting system.

3. Taxpayers who make incorrect declarations resulting in a shortage of tax payable or an increase in tax exempted, reduced, or refunded, or who do not collect tax on exported or imported goods but do not fall under the cases specified in point e, point g of clause 4 of this Article and point b of clause 2 of Article 44 of this Law, in addition to paying the full amount of tax and late payment interest, will also be subject to administrative penalties for tax management violations in the following cases:

a) The taxpayer voluntarily discovers and supplements their declaration after the customs authority has announced the direct inspection of the customs documents for goods undergoing customs procedures or after 60 days from the date of clearance and before the time of post-clearance inspection, audit, or inspection of goods that have been cleared;

b) The customs authority discovers it during the customs procedures; discovers it during post-clearance inspection, audit, or inspection of cleared goods, and the individual or organization in violation voluntarily remedies the consequences by paying the full amount of tax required by law;

c) Cases that do not fall under points a and b of this clause where the taxpayer voluntarily pays the full amount of tax required by law.

4. Tax evasion acts:

a) Failure to submit a tax registration dossier; failure to submit a tax declaration; submitting a tax declaration dossier more than 90 days after the deadline for submitting the tax declaration or the extended deadline for submitting the tax declaration as prescribed by this Law, resulting in underpayment of tax or an increase in the amount of tax exemption, reduction, or refund;

b) Failure to record or account in the accounting books for revenue related to the determination of the tax payable;

c) Failure to issue invoices and declare taxes when selling goods or services as prescribed by law, or recording a lower value on the sales invoice than the actual payment value of the goods or services sold for tax declaration purposes;

d) Using illegal invoices and documents, illegally using invoices and documents to account for goods and services purchased in activities that incur tax obligations, resulting in a reduction of the payable tax amount or an increase in the exempted tax amount, the reduced tax amount or increased deductible tax amount, the refundable tax amount, or the non-payable tax amount;

d) Using documents or materials that do not reflect the true nature of the transaction or the actual transaction value to incorrectly determine the amount of tax payable, tax-exempt amount, tax-reduced amount, tax-refunded amount, or tax not payable;

e) Incorrectly declaring the actual exported or imported goods where the individual or organization violating does not voluntarily remedy the consequence by paying the full amount of tax payable as required;

g) Intentionally failing to declare or falsely declaring taxes on exported or imported goods;

h) Colluding with consignors to import goods for the purpose of tax evasion;

i) Using goods that are tax-exempt or considered for tax exemption for purposes not according to regulations without declaring the change of usage purpose to the tax authorities;

k) Taxpayers conducting business activities during suspension or temporary cessation of business without notifying the tax authorities;

l) Taxpayers shall not be penalized for tax evasion but shall be penalized for violations of tax procedures in the following cases: failing to submit a tax registration dossier; failing to submit a tax declaration dossier; submitting a tax declaration dossier more than 90 days after the deadline for submitting the tax declaration dossier or after the extended deadline for submitting the tax declaration dossier, but no tax is payable; submitting a tax declaration dossier more than 90 days after the deadline for submitting the tax declaration dossier or after the extended deadline for submitting the tax declaration dossier with tax payable, and the taxpayer has fully paid the tax and late payment fees to the state budget before the time the tax authority announces the tax audit decision or before the tax authority prepares the minutes on the late submission of the tax declaration dossier.

5. The government shall provide detailed regulations on this Article.

Article 46. Handling violations of credit institutions, foreign bank branches, payment service providers, intermediary payment service providers, taxpayers' guarantors, organizations, and individuals involved in the field of tax administration

1. Credit institutions, foreign bank branches, payment service providers, and intermediary payment service providers that fail to fulfill the responsibility of transferring money from the taxpayer's account to the state budget account for the taxpayer's payable tax amount as requested by the tax authority shall be fined an amount corresponding to the money not transferred to the state budget account, except in cases where the taxpayer's accounts have no remaining balance or the entire balance of the taxpayer's account has been transferred to the state budget account but is still insufficient to cover the taxpayer's payable tax.

2. A guarantor who does not fulfill the guarantee obligation for the taxpayer in the event that the taxpayer fails to pay taxes must fulfill the taxpayer's obligation within the scope of the guarantee.

3. Organizations and individuals related to the implementation of tax law as prescribed in Clause 4, Article 2 of this Law, who collude or cover up taxpayers evading taxes, or fail to enforce coercive measures to implement administrative decisions on tax management, shall, depending on the nature and severity of the violation, be subject to administrative penalties or criminal liability in accordance with the provisions of the law.

4. Other organizations and individuals involved in the implementation of tax law as prescribed in Clause 4, Article 2 of this Law who fail to fulfill their responsibilities under the provisions of this Law shall, depending on the nature and level of the violation, be subject to administrative penalties or criminal liability in accordance with legal regulations.

5. The government shall provide detailed regulations on this Article.

Article 47. Authority to impose administrative penalties for tax management violations

1. The authority to impose administrative penalties for violations of tax procedures shall be exercised in accordance with the provisions of the law on handling administrative violations.

2. The head of the tax management agency has the authority to issue decisions on administrative penalties for acts prescribed in Articles 45 and 46 of this Law.

Section 2. ENFORCEMENT OF ADMINISTRATIVE DECISIONS

ON TAX MANAGEMENT

Article 48. Cases of enforcement of administrative decisions on tax management

1. Taxpayers who have tax debts for more than 90 days from the due date according to regulations.

2. Taxpayers who have tax debts when the extension period for payment of tax expires.

3. Taxpayers who have tax debts but do not operate at the registered address or engage in asset dispersal behavior.

4. Taxpayers who do not comply with the administrative penalty decision on tax administration within the time limit stated in the administrative penalty decision on tax administration, except in cases of deferment or temporary suspension of the execution of the penalty decision.

5. Taxpayers who have been administratively sanctioned for failing to comply with the tax inspection decision but continue to not comply with the tax inspection decision.

6. Tax enforcement measures have not been carried out on the tax debt of the taxpayer, and the tax authority does not calculate late payment interest as prescribed; the taxpayer is allowed to pay the tax debt in installments within a period not exceeding 12 months from the date the competent authority issues a document approving the installment payment of the tax debt and during the period the guarantee letter is valid. The installment payment of the tax debt is considered by the head of the tax authority based on the taxpayer's proposal and must be guaranteed by a credit institution.

7. Enforcement measures are not carried out against taxpayers with customs fees and fees for goods and transit transport vehicles.

8. The tax authority does not carry out enforcement measures on tax debt amounts offset through tax refunds that the tax authority is processing for offset for the taxpayer.

9. The head of the tax administration agency shall base on the actual situation to decide cases of enforcing administrative decisions on tax administration.

10. The Government shall provide detailed regulations on this Article.

Article 49. Measures for enforcing administrative decisions on tax administration

1. Measures for enforcing administrative decisions on tax administration include:

a) Withdrawing money from the account of the subject being enforced on at credit institutions, branches of foreign banks; freezing the account;

b) Deductions from part of salary or income;

c) Stopping customs procedures for exported or imported goods;

d) Halting the use of invoices;

e) Collecting money or other assets of the subject being enforced that are held by other agencies, organizations, or individuals;

f) Seizing assets, auctioning seized assets according to the provisions of law;

g) Filing a petition to apply bankruptcy procedures;

h) Revoke business registration certificates, enterprise registration certificates, cooperative registration certificates, cooperative group registration certificates, household business registration certificates, establishment and operation licenses, practice licenses, branch and representative office operation registration certificates, business location registration certificates, registration or licenses for e-commerce platform business activities.

2. The measures for enforcement of administrative decisions on tax management specified in Clause 1 of this Article shall cease to take effect from the time when:

a) The tax debt being enforced has been fully paid into the state budget;

b) The tax management authority or a competent state agency issues a document exempting, reducing, not collecting, allowing installment payments, extending deadlines, or not calculating late payment interest;

c) A competent state agency issues a document requesting the cessation of the enforcement decision;

d) The taxpayer has complied with the tax inspection decision in cases specified in Clause 5, Article 48 of this Law.

3. The decision to enforce the administrative decision on tax administration must be sent to the taxpayer subject to enforcement and relevant organizations and individuals. In cases where there is sufficient electronic infrastructure to serve electronic transmission and reception, the decisions to enforce administrative tax decisions are sent electronically to the taxpayer and relevant organizations and individuals for execution.

4. The tax authority, when filing a petition to apply bankruptcy procedures against a taxpayer subject to enforcement under regulations, is not required to pay bankruptcy fees or advance bankruptcy costs.

5. The Government shall provide detailed regulations on this Article and the order of implementing enforcement measures.

Article 50. Authority to decide on the enforcement of administrative decisions on tax administration

1. The head of the competent tax administration agency has the authority to:

a) Issue a decision to enforce the execution of administrative decisions on tax management regarding the coercive measures prescribed in points a, b, c, d, and đ, clause 1, Article 49 of this Law;

b) Submit a request for the application of bankruptcy procedures prescribed in point g, clause 1, Article 49 of this Law in accordance with the laws on rehabilitation and bankruptcy;

c) Propose that the competent authority implement the measures prescribed in point h, clause 1, Article 49 of this Law.

2. Chairpersons of People's Committees at all levels issue decisions to enforce administrative decisions on tax management regarding the coercive measures of asset seizure and auction of seized assets upon the request of the tax administration agency.

3. The government shall provide detailed regulations on this Article.

Chapter IX. IMPLEMENTING PROVISIONS

Article 51. Supplement Article 70a after Article 70 of the Accounting Law No. 88/2015/QH13, as amended and supplemented under Law No. 38/2019/QH14 and Law No. 56/2024/QH15.

Add Article 70a after Article 70 as follows:

"Article 70a. Providing accounting services by organizations offering tax procedure services

Organizations providing tax procedure services are allowed to provide accounting services to ultra-small enterprises, business households, and business individuals when there is at least one person holding an accountant certificate."

Article 52. Implementation provisions

1. This Law takes effect from July 1, 2026, except for the provisions in clause 2 of this Article.

2. The provisions in Article 13 and the use of electronic invoices by business households and business individuals as stipulated in Article 26 of this Law shall take effect from January 1, 2026.

3. The Law on Tax Administration No. 38/2019/QH14, as amended and supplemented in certain articles by Law No. 56/2024/QH15 (hereinafter referred to as the Law on Tax Administration No. 38/2019/QH14), shall cease to be effective from the date this Law comes into effect, except for the provisions in Clause 1 and Clause 3 of Article 53 of this Law; specifically, the provision in Article 51 of the Law on Tax Administration No. 38/2019/QH14 shall cease to be effective from January 1, 2026.

4. The tax authorities are responsible for organizing the development, upgrading, and completion of the information system to serve the full implementation of electronic transactions in tax administration. The application of all forms of electronic transactions in the field of tax administration shall be carried out according to the roadmap stipulated by the Minister of Finance, ensuring completion before January 1, 2027.

5. The government shall detail the provisions and clauses assigned in this Law and guide the implementation of this Law according to functions and responsibilities to ensure management requirements; it shall regulate tax management for transactions between affiliated enterprises; it shall regulate the handling of administrative violations regarding fees and charges in the field of tax management.

Article 53. Transitional Provisions

1. Tax amounts exempted, reduced, or not collected in accordance with the provisions of the law at each period, arising before July 1, 2026, shall continue to be handled according to the provisions of the Law on Tax Administration No. 38/2019/QH14.

2. Tax debts due until June 30, 2026, shall be handled in accordance with the provisions of this Law.

3. Inspections with inspection decisions issued before the effective date of this Law but for which conclusions or handling decisions have not yet been issued shall continue to be carried out according to the provisions of the Law on Tax Administration No. 38/2019/QH14.

This Law was passed by the National Assembly of the Socialist Republic of Vietnam, 15th Legislature, 10th Session, on December 10, 2025.

CHAIRMAN OF THE NATIONAL ASSEMBLY

(Signed)

Tran Thanh Man