Vietnam: Strengthening direct and indirect tax audits in 2026 for long-term loss-making and low-margin enterprises

The Department of Taxation (DoT) on March 31, 2026, issued Official Letter No. 1927/CT-KTr requiring provincial and municipal tax departments, the Large Enterprise Tax Division, and the e-commerce Tax Division to strengthen tax administration and implement thematic tax audits in 2026 for enterprises that have incurred losses over many years or operate with low profit margins.

In addition, the DoT on April 1, 2026, issued Decision No. 446/QĐ-CT, approving the 2026 specialized tax audit plan and a list of 108 enterprises subject to the program.

Under Official Letter No. 1927, enterprises that continuously declare losses over multiple years while still expanding investment, increasing charter capital, or maintaining significant revenue are identified as a key tax risk group and will be prioritized for inclusion in the tax audit plan. These enterprises are classified into two groups:

• Group 1: The managing tax authorities will immediately develop and implement tax audits at the taxpayers' premises during 2026.
• Group 2: Comprising enterprises with annual revenue of VND 1,000 billion or more that incurred losses consecutively in 2023 and 2024, the managing tax authorities will continue to analyze business results and corporate income tax (CIT) finalization dossiers for 2025 to identify high-risk enterprises and determine their inclusion in the 2026 tax audit plan.

The tax audits will focus on assessing the relationship between revenue, costs, and profits; examining the timing and basis for revenue recognition and output value added tax (VAT); reviewing VAT declarations; and examining costs and related party transactions. According to the plan, tax authorities will conduct the audits starting from April 2026 and complete them no later than December 2026.

Read an April 2026 report prepared by the KPMG member firm in Vietnam