- 40 Q&As â Official set
- 1 Jul 2026 â Circular 89/2026 in force
- Circ. 80/2021 â Replaced
- 10 â 7 days â Faster procedures
đ Circular 89/2026/TT-BTC and the 40-question Q&A
Circular 89/2026/TT-BTC was issued by Vietnam's Ministry of Finance on 30 June 2026 and took effect on 1 July 2026. It guides the Law on Tax Administration No. 108/2025/QH15 and Decree 252/2026/ND-CP, and replaces Circular 80/2021/TT-BTC.
On 6 October 2026, the Tax Department issued Official Letter 7404/CT-PC on communicating the 2025 Law on Tax Administration. Its Appendix 1 contains 40 questions and answers on what taxpayers need to know under Circular 89/2026/TT-BTC, in 8 groups. Below is a summary of all 40, each with its legal basis.
đ 40 tax Q&As under Circular 89/2026/TT-BTC (Vietnamese) â Key rules taxpayers need to know - Word file (.docx). Tải váť
Key changes
- â No resubmitting documents the tax authority already holds; the system may pre-fill returns
- â No more monthly PIT filing for withholding organizations
- â Several procedures cut from 10 to 7 days
- â Household businesses can claim refunds of overpaid VAT and PIT
- â Remote online tax inspections on electronic data
đ For foreign-invested companies: questions 15-17 (country-by-country report, quarterly PIT, PIT allocation) and 22-23 (foreign suppliers and withholding on digital platforms) are most relevant to FDI groups operating in Vietnam.
â All 40 questions and answers
Tap a question to see the answer, or type a keyword to filter. Translations are unofficial.
đť E-transactions and tax dossiers
Câu 1. Do taxpayers have to resubmit documents the tax authority already holds?
No. Taxpayers need not resubmit documents or re-declare information the tax authority already has, including data shared from national and ministry databases. They only supplement or correct missing or inaccurate data.
Basis: Article 6 Circular 89/2026/TT-BTC
Câu 2. Can the tax authority auto-generate a return when the system has complete data?
Yes. When the tax system holds sufficient information and documents to determine tax, it can automatically prepare the return to assist the taxpayer.
Basis: Article 6 Circular 89/2026/TT-BTC
Câu 3. Can an electronic identity account (VNeID) be used for e-tax transactions?
Yes. Taxpayers eligible for an electronic identity account may use it to carry out electronic tax transactions.
Basis: Articles 8, 13 Circular 89/2026/TT-BTC
Câu 4. How soon must changes to e-transaction registration be updated?
Within 3 working days of the change, the taxpayer must update the tax authority.
Basis: Article 13 Circular 89/2026/TT-BTC
Câu 5. Does the system's automatic acknowledgment mean the filing was accepted?
No. It only confirms receipt. Taxpayers must still watch for the acceptance or rejection notice and any requests for supplements or explanations.
Basis: Article 11 Circular 89/2026/TT-BTC
Câu 6. How quickly must the tax authority confirm receipt of an e-filing?
Normally within 1 working day of the system recording the submission; for refund, exemption and reduction dossiers, refund cancellations and returns that double as refund claims, within 3 working days.
Basis: Article 11 Circular 89/2026/TT-BTC
𧞠VAT filing for enterprises and organizations
Câu 7. How does a new business determine its VAT filing period?
It tracks revenue in its first calendar year. If revenue exceeds VND 50 billion (even with less than 12 months of operation), it files VAT monthly from the following calendar year.
Basis: Article 19 Circular 89/2026/TT-BTC
Câu 8. What if a business no longer qualifies for quarterly VAT filing?
Switch to monthly filing from the first month of the next quarter, re-file the months of the incorrectly filed quarter, and determine any tax and late-payment interest due.
Basis: Article 19 Circular 89/2026/TT-BTC
Câu 9. In a supplementary filing, is only the erroneous period amended?
Not only. The business must determine whether the error qualifies for supplementary filing, assess its effect on tax payable, deductible VAT and refunds claimed, and decide whether it must be declared in the period the error was found.
Basis: Article 17, Appendix II Circular 89/2026/TT-BTC
Câu 10. Where does a relocating business file if relocation is not complete?
If a filing deadline falls before the address change is completed with the business registry or the new tax office, the business still files with the tax office it is moving from.
Basis: Article 17 Circular 89/2026/TT-BTC
Câu 11. Where does an investment project claiming a VAT refund file?
Same-province projects file with the managing tax office (taxpayers managed by the Large Taxpayers or E-commerce Tax Sub-departments file with the provincial tax office where the project is). Out-of-province projects file where the project is. Multi-province projects depend on whether a project management board, branch or entity manages them.
Basis: Article 19 Circular 89/2026/TT-BTC
Câu 12. Can a dependent unit in the same province as head office file VAT separately?
Yes, if it has its own seal and bank account, sells directly, uses invoices registered with its tax office, fully accounts for input and output VAT, and wishes to file separately.
Basis: Article 19 Circular 89/2026/TT-BTC
đ˘ Corporate and personal income tax
Câu 13. Must a business being split finalize CIT at the split date?
No. Under the amendment, a business being split is no longer required to finalize corporate income tax at the split date.
Basis: Article 21 Circular 89/2026/TT-BTC
Câu 14. Must a converted business that inherits all tax obligations finalize CIT at conversion?
No. It finalizes at year-end as normal.
Basis: Article 21 Circular 89/2026/TT-BTC
Câu 15. Is the country-by-country profit report still part of the CIT finalization dossier?
No. Because deadlines differ, it is no longer part of the dossier; businesses required to prepare it follow the separate related-party transaction rules.
Basis: Article 21 Circular 89/2026/TT-BTC
Câu 16. Do withholding organizations still file PIT monthly?
No. Forms 05/KK-TNCN (payers) and 02/KK-TNCN (individuals filing directly) no longer have a monthly period; from 1 July 2026 filing is quarterly with annual finalization.
Basis: Article 22 Circular 89/2026/TT-BTC
Câu 17. Must PIT be allocated to dependent units in other provinces?
Not in every case. The organization may file centrally at head office and determine each location's tax, or file separately for each location.
Basis: Article 22 Circular 89/2026/TT-BTC
Câu 18. For capital-transfer PIT filed by an organization, must cost evidence be attached?
No. Evidence of transfer price, purchase price and related costs is kept by the organization rather than attached to the return.
Basis: Article 22 Circular 89/2026/TT-BTC
đŞ Household businesses, individuals and e-commerce
Câu 19. What does a household business's supplementary filing contain?
The tax return for the period with the error, supplemented under the rules specific to household and individual businesses.
Basis: Article 17 Circular 89/2026/TT-BTC
Câu 20. When must insurance, lottery, multi-level sales agents and brokers file themselves?
When they owe tax but no organization withheld or filed on their behalf during the year; obligations depend on the cooperation model and the paying organization's duties.
Basis: Article 22 Circular 89/2026/TT-BTC
Câu 21. Are household businesses with very small tax amounts exempt?
Certain taxes and fees are exempt if the annual amount on the return or finalization is VND 50,000 or less and the case is listed in Decree 252/2026/ND-CP. It is not an automatic exemption for every amount under VND 50,000.
Basis: Article 65 Circular 89/2026/TT-BTC
Câu 22. Must foreign suppliers disclose their Vietnamese customers?
Yes. Their tax returns must include a detailed list of Vietnamese customers, with identification details.
Basis: Article 31 Circular 89/2026/TT-BTC
Câu 23. Must Vietnamese businesses withhold for foreign suppliers on digital platforms?
Yes. Vietnamese organizations using the VAT credit method must withhold and pay VAT, CIT and PIT for foreign suppliers or non-resident individuals selling via e-commerce or digital platforms. If they withheld on a transaction through a platform with ordering and payment functions, they must notify the platform electronically to avoid double withholding.
Basis: Article 32 Circular 89/2026/TT-BTC
Câu 24. Where do e-commerce platform operators with ordering and payment functions file?
With the E-commerce Tax Sub-department.
Basis: Article 33 Circular 89/2026/TT-BTC
đł Payment, offset and tax-obligation confirmation
Câu 25. How are payments made with a payable ID offset?
The tax system automatically offsets the payment against the matching obligation.
Basis: Articles 36, 42 Circular 89/2026/TT-BTC
Câu 26. Is an overpayment without a payable ID offset automatically?
No. The taxpayer must select the overpayment and offset it against a specific debt or payable that has an ID.
Basis: Article 42 Circular 89/2026/TT-BTC
Câu 27. What can taxpayers ask the tax authority to confirm?
Two items: tax still owed to the state budget and tax already paid.
Basis: Article 44 Circular 89/2026/TT-BTC
Câu 28. What if the requested figures differ from tax authority data?
The authority confirms or declines based on its tax management system data, and must give reasons when it declines.
Basis: Article 44 Circular 89/2026/TT-BTC
Câu 29. Have processing times changed for deferral, late-payment interest and penalty dossiers?
Yes, cut from 10 to 7 days for deferrals, other revenues, late-payment interest, penalties and non-calculation or exemption of interest.
Basis: Articles 38, 40, 41 Circular 89/2026/TT-BTC
đ° Refunds and overpayment refunds
Câu 30. What does an export VAT refund dossier contain?
Form 01/GTGT with the refund indicators completed plus Appendix 01-8/GTGT, from the date the tax system is upgraded to accept them.
Basis: Article 46 Circular 89/2026/TT-BTC
Câu 31. What does an investment-project VAT refund dossier contain?
Form 02/GTGT with refund indicators, Appendix 01-8/GTGT and project documents; documents submitted with the first refund are resubmitted only if they change.
Basis: Article 46 Circular 89/2026/TT-BTC
Câu 32. Is there a separate refund dossier for producers subject to 5% VAT?
Yes. It consists of Form 01/GTGT with refund indicators and Appendix 01-8/GTGT.
Basis: Article 46 Circular 89/2026/TT-BTC
Câu 33. If only part of a refund claim is high-risk, is the whole dossier audited first?
No. The dossier is classified part by part; the full amount is not automatically treated as high-risk.
Basis: Article 48 Circular 89/2026/TT-BTC
Câu 34. What if the full refund amount cannot be justified?
For pre-refund audit dossiers, if the taxpayer misses the deadline to explain or prove it, the authority determines the non-refundable portion; the eligible portion is still processed.
Basis: Articles 49, 59 Circular 89/2026/TT-BTC
Câu 35. Can a refund be offset against next period's tax?
Yes. The authority offsets it on the taxpayer's written request.
Basis: Article 49 Circular 89/2026/TT-BTC
Câu 36. Can household businesses get refunds of overpaid VAT or PIT?
Yes. The circular adds refund dossiers for overpaid VAT and PIT for household and individual businesses in specified cases.
Basis: Article 56 Circular 89/2026/TT-BTC
đ Exemptions, reductions and installments
Câu 37. For a family-relationship registration-fee exemption, must proof be submitted immediately?
No. The authority first checks the National Population Database; proof is needed only if the data cannot be retrieved.
Basis: Article 74 Circular 89/2026/TT-BTC
Câu 38. Are tax-reduction dossiers for disasters, epidemics, fires and accidents simplified?
Yes. Depending on the tax and case, documents such as appraisal minutes or financial statements are no longer required; the taxpayer declares the extent and value of damage with necessary confirmations.
Basis: Articles 68-73 Circular 89/2026/TT-BTC
Câu 39. How long does processing an installment-payment dossier take?
Cut from 10 to 7 working days.
Basis: Article 86 Circular 89/2026/TT-BTC
đ Tax inspections
Câu 40. Does the circular provide for remote online tax inspections on electronic data?
Yes. The process includes opening a connection gateway, exchanging and storing data, logging, and closing the gateway at the end; inspectors may switch to on-site inspection when physical verification is needed.
Basis: Article 89 Circular 89/2026/TT-BTC
â What taxpayers should do
- Update e-transaction details within 3 working days: When your email, phone or registered digital signature for e-tax changes.
- Watch for the acceptance notice, not just the auto-acknowledgment: An automatic reply is not acceptance - check the acceptance notice and any requests for explanation.
- Companies: review PIT and VAT filing periods: Move PIT filing to quarterly; monitor the VND 50 billion revenue threshold for VAT periods.
- Pay using the payable ID: So the system offsets the right obligation; for overpayments without an ID, select the offset yourself.
- Keep electronic records complete: Complete e-invoices, vouchers and books prepare you for remote online inspections.
â FAQ on Circular 89/2026/TT-BTC
When did Circular 89/2026/TT-BTC take effect?
It was issued on 30 June 2026 and took effect on 1 July 2026, replacing Circular 80/2021/TT-BTC.
What does Circular 89/2026/TT-BTC guide?
The Law on Tax Administration No. 108/2025/QH15 and Decree 252/2026/ND-CP.
Who issued the 40 Q&As?
Vietnam's Tax Department, in Appendix 1 of Official Letter 7404/CT-PC dated 6 October 2026.
Do companies still file PIT monthly from 1 July 2026?
No. Forms 05/KK-TNCN and 02/KK-TNCN no longer have a monthly period (Article 22).
Do household businesses pay tax amounts under VND 50,000?
Certain taxes and fees are exempt if the annual amount is VND 50,000 or less and the case is listed in Decree 252/2026/ND-CP; it is not automatic for every amount (Article 65).
đ° Legal basis and sources
- Táťng hᝣp báť 40 câu háťi ÄĂĄp váť thuáşż theo ThĂ´ng tĆ° 89/2026/TT-BTC (16/10/2026) - thuvienphapluat.vn
- ThĂ´ng tĆ° 89/2026/TT-BTC vĂ táťng hᝣp cĂĄc Äiáťm máťi váť quản lĂ˝ thuáşż tᝍ 01/07/2026 - amis.misa.vn
- Thông tư 89/2026/TT-BTC thay thế Thông tư 80/2021 tᝍ ngà y 1/7/2026 - thuvienphapluat.vn
- CĂ´ng vÄn 7404/CT-PC ngĂ y 06/10/2026 cᝧa C᝼c Thuáşż - Ph᝼ l᝼c 1 - thuvienphapluat.vn
âšď¸ Summarized from the Tax Department's Q&A (Appendix 1, Letter 7404/CT-PC) and Circular 89/2026/TT-BTC (Vietnamese originals; unofficial translation), for reference only. Check the originals and confirm with your tax office before applying.
