Circular 94/2026/TT-BTC compliance and risk management in tax administration

CIRCULAR

Providing compliance management and risk management in tax administration

Pursuant to the Law on Tax Administration No. 108/2025/QH15;

Pursuant to the Government’s Decree No. 252/2026/ND-CP detailing a number of articles of, and measures for organizing and guiding the implementation of, the Law on Tax Administration;

Pursuant to the Government’s Decree No. 254/2026/ND-CP detailing a number of articles of, and measures for organizing and guiding the implementation of, the Law on Tax Administration No. 108/2025/QH15 regarding e-invoices and e-documents;

Pursuant to the Government’s Decree No. 29/2025/ND-CP defining the functions, tasks, powers and organizational structure of the Ministry of Finance, amended and supplemented under Decree No. 166/2025/ND-CP;

At the proposal of the Director General of the Taxation Department,

The Minister of Finance promulgates the Circular providing compliance management and risk management in tax administration.

Chapter I

GENERAL PROVISIONS

Article 1. Scope of regulation

This Circular provides for:

1. The collection, processing, management and use of information related to taxpayers for compliance management and risk management in tax administration.

2. Criteria for assessment, classification of risk levels and the application of risk management in professional tax administration operations specified in Clause 5, Article 33 of the Law on Tax Administration No. 108/2025/QH15.

3. Criteria for assessment of law compliance by taxpayers and compliance management activities in tax administration specified in Clause 3, Article 34 of the Law on Tax Administration No. 108/2025/QH15.

Article 2. Subjects of application

1. Taxpayers.

2. Tax offices.

3. Tax officers.

4. State agencies, organizations and other individuals related to tax administration activities.

Article 3. Interpretation of terms

In this Circular, the terms below are construed as follows:

1. Information for compliance management and risk management in tax administration means tax information, tax-related information, and information related to taxpayers that is collected and processed by tax offices for compliance management and risk management in tax administration.

2. Tax law compliance level means the result of assessment and classification made by tax offices regarding full, timely and proper performance of obligations of taxpayers prescribed by the tax laws throughout the processes of tax registration, tax declaration, tax payment, tax reporting, and provision of information to tax offices.

3. Criteria for assessment and classification of tax law compliance levels means the system of standards and indicators used for assessing and classifying Levels of tax law compliance by taxpayers.

4. Index of criteria for assessment and classification of tax law compliance levels means information indicators bearing specific values of the criteria for assessment and classification of levels of tax law compliance by taxpayers.

5. Assessment and classification of tax law compliance levels means the analysis of information and data to determine level of compliance with the tax laws by taxpayers and classify taxpayers into different compliance groups.

6. Risk level means a measure reflecting the likelihood of occurrence and the degree of impact of non-compliance with the tax laws by taxpayers on the performance of tax obligations and tax administration by tax offices.

7. Criteria for assessment and classification of risk levels means the system of standards and indicators used for assessing and classifying taxpayers according to the levels of risks of violations of tax laws.

8. Indexes of criteria for assessment and classification of risk levels mean information indicators bearing specific values of the criteria for assessment and classification of risk levels.

9. Assessment and classification of risk levels of taxpayers means the analysis, measurement and determination of the potential level of acts of non-compliance with the tax laws by taxpayers and the classification of taxpayers into different risk groups.

10. Sign of risk means a factor of informative value that reflects the potentiality of acts of law violation.

11. Sign of tax law violation means a factor of informative value serving as a basis for identifying acts of violation of the tax laws.

12. Sentinel supervision means the application by a tax office of professional tax administration measures to closely monitor and control the activities of taxpayers showing signs of high risks or signs of violations of the tax laws during a given period.

13. Tax compliance and risk management subsystem means a specialized functional layer of the Tax administration system of the tax sector, developed to serve the collection, processing and analysis of information; the assessment and classification of levels of tax law compliance by taxpayers and risk levels of taxpayers; and to support the proposal, coordination, supervision, traceability and feedback of the results of application of tax administration measures in accordance with law.

The tax compliance and risk management subsystem comprises functions, data, electronic records, compliance dossiers and cases, the risk register, sets of criteria, indexes, professional rules, analytical models, warning and forecasting tools, and decision-support tools; and shall be centrally managed and operated, with access and use decentralized according to the functions, tasks and powers of tax offices at all levels.

The tax compliance and risk management subsystem does not replace the decision-making responsibility of competent tax offices and tax officers. The exploitation and use of analytical results, warnings and proposals generated by the subsystem shall ensure objectivity, transparency, traceability, accountability, confidentiality of taxpayer information, protection of personal data, information system security, and compliance with relevant laws.

14. Classification by machine learning method means the application of computational and statistical algorithms on computers to identify models, functions and indicators for classifying and forecasting risk levels.

15. List-based ranking method means a method of assessing taxpayers through comparison with criteria and indexes concerning their operation and compliance with the tax laws, arranged into groups corresponding to each ranking level. A taxpayer shall attain a specific ranking level if it/he/she is assessed as satisfying the criteria and indexes corresponding to that ranking level.

16. Scoring method and score-based classification means a method of assessing taxpayers based their score of criteria and indexes on their operation and tax law compliance.

17. Risk register means the database storing information on risks in the tax compliance and risk management subsystem, allowing to search for definitions, consequence levels, the number and categories of taxpayers related to each risk; assessment reports, criteria and scoring rules; together with plans and handling measures appropriate to the scale and ranking of each risk after analysis.

Article 4. Principles of compliance management and risk management in tax administration

1. The application of compliance management and risk management in tax administration shall ensure objectivity, transparency, compliance with law and non-discrimination; and shall be carried out to improve the efficiency and effectiveness of tax administration, encourage and create favorable conditions for taxpayers to voluntarily comply with the tax laws, and prevent, detect and promptly handle acts of violation of the tax laws.

2. Compliance management and risk management in tax administration shall be carried out on the basis of objective, comprehensive and regularly updated data analysis; shall be applied management measures appropriate to the characteristics, tax law compliance levels and risk levels of each group of taxpayers and each taxpayer; and priority shall be given to the application of modern information technology and automation in data collection, data processing, assessment and classification.

3. Information serving compliance management and risk management shall be collected from information sources inside and outside tax offices, including information from overseas in accordance with law and Article 6 of this Circular; shall be managed through the tax administration system of the tax sector and concurrently processed, shared and provided to tax offices at all levels and related state agencies for the purpose of state management in accordance with law.

4. The assessment and classification of levels of tax law compliance by taxpayers and risk levels of taxpayers shall be carried out automatically and periodically by using one of or combining the methods specified in this Circular based on professional tax administration processes and measures, the system of criteria and the taxpayer database.

5. In case the tax compliance and risk management subsystem encounters an incident or fails to satisfy the requirements for the application of compliance management and risk management in tax administration, it shall be carried out manually on the basis of written approval by a competent person in accordance with the Law on Tax Administration No. 108/2025/QH15 and guiding documents.

6. Where there is any change in information that results in a change to the assessment and classification of the taxpayer’s level of tax law compliance and tax risk level while the application system has not yet automatically updated, the adjustment shall be made manually by tax officers after obtaining approval from a competent person.

7. Based on the results of assessment and classification of levels of tax law compliance by taxpayers and risk levels of taxpayers, tax offices shall:

a) Decide on examination, supervision and the application of appropriate professional tax administration measures;

b) Formulate plans and measures to improve the overall level of compliance, suitable to available resources, based on analyzing the nature of acts, reasons and scale of each compliance level and risk level.

8. Results of the application of professional measures corresponding to each taxpayer’s tax law compliance level and risk level shall be fully and accurately updated to tax administration support applications or the tax compliance and risk management subsystem of tax offices for each specific case, serving as the basis for improving the mechanism for, and the assessment and classification of, levels of tax law compliance by taxpayers and risk levels of taxpayers in subsequent assessment periods.

9. Tax officials shall be exempt from personal liability for acts performed in the course of their duties in accordance with this Circular and the guidelines on compliance management and risk management.

Article 5. Methods of assessment

Levels of tax law compliance by taxpayers and risk levels of taxpayers shall be determined by using one of or combining the following methods:

1. Scoring method and score-based classification.

2. Machine learning method.

3. List-based ranking method.

Article 6. Collection and processing of information for compliance management and risk management in tax administration

1. Information for compliance management and risk management in tax administration

Information serving compliance management and risk management in tax administration includes:

a) Information in tax offices:

a.1) Information about tax registration; owners of taxpayers; labor registration and employment; information on status of taxpayers; number of changes in business registration and tax registration information; capital contribution by members; capital contribution relationships; affiliated relationships; and principal business lines;

a.2) Information about tax declaration dossiers; tax payment; tax arrears; tax incentives; tax exemption and reduction; extension of tax payment deadlines; installment tax payment; tax refund; registration, management and use of invoices and documents; information on complaints and denunciations; information on results of inspection, examination, audit, investigation and post-inspection, post-examination, post-audit and post-investigation handling; and information on related-party transactions;

a.3) Other information.

b) Information collected from state agencies, organizations and individuals responsible for providing information:

b.1) Information about taxpayers collected from related state agencies, organizations and individuals in accordance with Decree No. 252/2026/ND-CP;

b.2) Information from overseas and information provided by international organizations in accordance with obligations under tax-related treaties to which the Socialist Republic of Vietnam is a contracting party.

c) Other information relating to taxpayers.

2. Collection and processing of information for compliance management and risk management

a) Sources of information collection:

a.1) Via information systems in tax offices;

a.2) Through the coordination in information exchange with agencies and units of the Ministry of Finance and agencies and units of other ministries, sectors and related agencies;

a.3) Through the coordination in information exchange with foreign tax offices and competent authorities in accordance with law;

a.4) Through the receipt of information from state agencies and provided by organizations and individuals in accordance with law;

a.5) Information about activities of taxpayers collected in the course of tax administration;

a.6) Information obtained from surveys, assessments and public opinion investigations conducted by political organizations, socio-political organizations or reputable domestic and international organizations;

a.7) Purchase of information in accordance with the Law on Tax Administration No. 108/2025/QH15 and guiding documents;

a.8) Through the receipt of tax-related information from overseas and information provided by international organizations in accordance with obligations under treaties to which Vietnam is a contracting party;

a.9) Other related information sources prescribed by law.

b) Modes of information collection:

b.1) Provision or exchange of information in the form of electronic data, electronic documents, electronic mail (e-mail), exchange through the Taxation Department’s e-portal, the National public service portal; text messages and telephone calls made to telephone numbers officially announced by tax offices;

b.2) Provision or exchange of information in writing, by telex, telegram, facsimile, or paper documents;

b.3) Direct exchange based on written records certified by related parties; appointment of representatives to work, conduct verification and collect information and documents; organization of conferences and other forms.

c) Processing of collected information:

c.1) Evaluation of the relevance of information to the needs and purposes of information use; examination of the reliability and accuracy of information;

c.2) Classification, arrangement and storage of information obtained from different sources by information groups for exploitation and analysis;

c.3) Analysis of information, review and identify information components serving compliance management and risk management;

c.4) Summarization and linkage of relevant factors identified through analysis to clarify the contents and value of collected information, serving the analysis, assessment and classification of levels of tax law compliance by taxpayers and risk levels of taxpayers.

Article 7. Operation of the tax compliance and risk management subsystem

1. The tax compliance and risk management subsystem shall be centrally managed and operated within the tax administration system of the tax sector; The Taxation Department shall act as the focal agency responsible for organizing its operation and assigning access and use rights to tax offices at all levels in accordance with their functions, tasks and powers.

The tax compliance and risk management subsystem shall be connected to, integrated with, and shared data with other functional layers, subsystems, databases and professional applications of the tax sector in accordance with the architecture, technical standards, regulations on management and operation, and the provisions of law.

2. The tax compliance and risk management subsystem shall operate on the basis of the tax sector’s digital data platform, electronic records, compliance dossiers/cases of taxpayers, the risk register, sets of criteria, indexes, professional rules, analytical models, and other relating lawful data sources.

The receipt, updating, processing and exploitation of data on the tax compliance and risk management subsystem shall be carried out in real time, near real time, or periodically or under a connection mechanism appropriate to the nature of each data source, technical conditions, tax administration requirements and the provisions of law.

3. The tax compliance and risk management subsystem shall automatically or semi-automatically perform functions serving compliance management and risk management in tax administration, including:

a) Receiving, collecting, verifying, standardizing, reconciling, consolidating, storing and exploiting information and data serving compliance management and risk management;

b) Recording, updating and monitoring events arising during tax administration that are related to levels of tax law compliance by taxpayers and risk levels of taxpayers;

c) Creating, updating, managing and monitoring the life cycle of electronic records, compliance dossiers/cases and risk dossiers of taxpayers;

d) Identifying, analyzing, assessing, scoring and classifying levels of tax law compliance by taxpayers and risk levels of taxpayers according to the criteria, indexes, methods and professional rules promulgated by competent authorities;

dd) Detecting and warning of signs of risks and signs of violations of tax laws; analyzing trends, behaviors, relationships, networks and potential risk models;

e) Proposing handling strategies, professional tax administration measures, plans of intervention, supervision or examination appropriate to levels of tax law compliance, risk levels and the characteristics of each taxpayer group and each taxpayer;

g) Monitoring, supervising, tracing, summarizing, assessing and providing feedback on the results of application of tax administration measures for updating criteria, indexes and analytical models and improving the effectiveness of compliance management and risk management in subsequent assessment periods.

4. The tax compliance and risk management subsystem shall apply data analytics, big data, machine learning, artificial intelligence and other appropriate technologies to support information processing, analysis, warning, forecasting and the proposal of professional measures.

The results of analysis, warning, forecasting, scoring, classification or proposals generated by the tax compliance and risk management subsystem shall serve as supporting grounds for competent tax offices and tax officers in considering, selecting, deciding on and implementing tax administration measures in accordance with law; shall not replace the responsibility of competent tax offices and tax officers for issuing tax administrative decisions or implementing professional tax administration measures.

The application of machine learning, artificial intelligence and analytical models in the tax compliance and risk management subsystem shall ensure objectivity, transparency, controllability, traceability and accountability; and shall be tested, assessed, supervised and updated in accordance with management requirements and relevant laws.

5. The results of processing, analysis, assessment, classification and warning generated by the tax compliance and risk management subsystem shall be exploited and used as follows:

a) For taxpayers: to support the provision of electronic tax services, provide early warnings of risks, make compliance recommendations, assist taxpayers in reviewing and rectifying errors, and improve voluntary tax law compliance;

b) For tax offices and tax officers: to provide information, data, dossiers, warnings, analytical results, classification results and proposed professional measures serving compliance management, risk management, planning of examinations and sentinel supervision, tax debt management, invoice and document management, tax refund management and other professional tax administration operations in accordance with law;

c) For related state agencies, organizations and individuals: the provision, exchange and sharing of information, data, risk warnings or signs of violations of the tax laws shall be carried out in accordance with the prescribed decentralization, competence, purposes of use, confidentiality requirements and relevant laws.

6. The Taxation Department shall promulgate regulations, procedures, standards and guidance on the management, operation and exploitation of the tax compliance and risk management subsystem; the management of data, electronic records, compliance dossiers/cases, the risk register, sets of criteria, indexes, professional rules and analytical models; and the assignment of access, exploitation, use and updating of information on the tax compliance and risk management subsystem.

The management, operation and exploitation of the tax compliance and risk management subsystem shall ensure information system security, cybersecurity, confidentiality of taxpayer information, protection of personal data, management of access logs, traceability of processing activities, dossier storage, clear allocation of responsibilities, and compliance with relevant laws.

In case the tax compliance and risk management subsystem encounters an incident, fails to satisfy operational requirements, or has not yet been integrated with necessary data sources, the Taxation Department shall organize the implementation of temporary handling measures, including the use of temporary forms or dossiers and the recording of the grounds, contents, time and person handling each case; the decisions on the application of temporary handling measures shall be approved by competent persons; after the tax compliance and risk management subsystem resumes operation, all information, data and results of temporary handling shall be fully updated, reconciled and synchronized with the tax compliance and risk management subsystem in accordance with regulations.

Article 8. Application of compliance management and risk management in tax administration

1. Tax offices shall, based on the results of the assessment and classification of tax law compliance levels specified in Article 10, the results of the assessment and classification of risk levels of taxpayers specified in Article 13 of this Circular, and professional information at the time of issuance of decisions, apply management measures in the following activities:

a) Compliance management in tax administration;

b) Risk management in tax registration;

c) Risk management in the examination of tax declaration dossiers and other revenue dossiers at headquarters of tax offices;

d) Risk management in tax refund and other revenue refund management;

dd) Risk management in examinations at offices of taxpayers;

e) Risk management in the management of tax arrears, other revenues, and the enforcement of tax administrative decisions;

g) Risk management in tax exemption and reduction management;

h) Risk management in invoice and document management;

i) Risk management for taxpayers subject to sentinel control and supervision;

k) Application of risk management in other professional tax administration operations.

2. The Taxation Department shall provide detailed guidance on the assessment and classification of levels of tax law compliance by taxpayers and risk levels of taxpayers to meet tax administration requirements in each period.

3. Results of the assessment and classification of compliance levels by taxpayers and risk levels of taxpayers shall be updated to the tax compliance and risk management subsystem. Tax offices at all levels shall summarize, update and manage compliance information, compliance dossiers of taxpayers and the risk register to serve tax administration throughout the tax sector.

4. In case suspicious information is obtained or signs of violations of the tax laws are detected through inspection, examination, audit, denunciations, or information provided by state agencies or investigation agencies, the heads of tax offices shall decide to change the form or level of examination or apply other tax administration measures within their competence and shall take responsibility for their decisions.

Article 9. Sentinel control and supervision of taxpayers showing signs of violations of tax laws

1. Taxpayers subject to sentinel tax supervision are those showing one of the following signs:

a) Taxpayers conduct banking transactions showing suspicious signs prescribed by the law on anti-money laundering that are related to tax evasion or tax fraud.

b) Taxpayers or their lawful representatives are prosecuted for acts of violation relating to taxes, invoices or documents.

c) Taxpayers show signs of high tax risks falling within a key compliance focus area or through information collected from tax administration activities requiring tax administration supervision.

d) Taxpayers are classified as non-compliant under Article 10 of this Circular; or taxpayers fail to provide explanations or additional information or provide explanations or additional information that do not fully satisfy the requirements or the time limit specified in the written notice of the tax office.

2. Tax offices at all levels shall monitor, supervise and apply professional tax administration measures appropriate to each case specified in Clause 1 of this Article.

3. The Taxation Department shall provide detailed guidance on the collection and analysis of information, identification of key supervision targets, supervision measures, and supervision periods in accordance with law in each period.

CHAPTER II

COMPLIANCE MANAGEMENT IN TAX ADMINISTRATION

Article 10. Classification of levels of tax law compliance by taxpayers

1. Taxpayers shall be assessed and classified into one of the following tax law compliance levels:

a) Level 1: High compliance.

b) Level 2: Medium compliance.

c) Level 3: Low compliance.

d) Level 4: Non-compliance.

2. Levels of tax law compliance by taxpayers shall be classified based on the criteria specified in Appendix I to this Circular.

3. Results of the assessment and classification of levels of tax law compliance by taxpayers shall be monitored and handled by tax offices as follows:

a) For taxpayers at the level of non-compliance, tax offices shall apply the management measures specified in Article 9 and the compliance improvement measures specified in Article 11 of this Circular;

b) For taxpayers at the level of high compliance, medium compliance, and low compliance, tax offices shall apply the compliance improvement measures specified in Article 11 of this Circular.

Article 11. Measures to improve tax law compliance by taxpayers

Based on the results of the classification of levels of tax law compliance by taxpayers specified in Article 10 of this Circular, tax offices shall analyze the nature of acts of taxpayers and the scale of each tax law compliance level, and formulate plans to improve tax law compliance with handling measures appropriate to each compliance issue as follows:

1. For taxpayers at the level of high compliance

a) To include them in the list of taxpayers to be considered and selected for commendation and rewarding in accordance with regulations applicable to taxpayers that properly comply with the tax laws.

b) To apply the priority regime in tax administration when they fully satisfy the conditions specified in Article 48 of Decree No. 252/2026/ND-CP.

2. For cases requiring improvement of compliance

a) To coordinate with state agencies, related organizations and tax agents in implementing compliance improvement measures and measures to support and guide taxpayers in carrying out tax procedures; to organize taxpayer contact programs, dialogue conferences and seminars to assist taxpayers in properly and fully performing their tax obligations;

b) To study and propose amendments and supplements to policies, simplify administrative procedures, implement support measures, and intensify the application of information technology to facilitate tax declaration of taxpayers and tax payment to save time and compliance costs of taxpayers;

c) To classify risk levels of taxpayers and apply tax administration measures corresponding to risk levels of taxpayers specified in Articles 13, 14, 15, 16, 17, 18, 19 and 20 of this Circular.

Article 12. Supervision and assessment of the implementation of compliance improvement plans

1. Contents of supervision and assessment

a) The organization of the implementation of tax law compliance improvement plans;

b) Results and effectiveness of the implementation of compliance improvement plans;

b.1) The efficiency and effectiveness of the handling measures implemented by tax offices at all levels on the basis of risk analysis and identification for each taxpayer group;

b.2) Comparison and assessment of actual results against expected results in implementing risk mitigation measures through compliance measurement.

c) The application of a transparent process in the formulation and implementation of compliance improvement plans;

d) The improvement of the overall compliance levels of taxpayer groups and different categories of tax obligations;

dd) Organizational structures and human resources of tax offices at all levels in implementing the plans to ensure the efficiency and effectiveness of tax administration in accordance with the set objectives.

2. Measures for supervision and assessment

a) To summarize, monitor and analyze information and statistical reports of tax offices at all levels, divisions and Tax Sub-departments under the Taxation Department during the implementation of compliance improvement plans;

b) To collect and summarize implementation results; analyze the impacts of the measures already implemented and propose adjustments and additional measures to improve the effectiveness of plan implementation; review and update the risk register, and remove risks that are no longer relevant;

c) To establish work teams to examine and assess the implementation of the plans at tax offices at all levels.

3. Responsibilities of units

The Director General of the Taxation Department shall assign units responsible for compliance management and risk management in tax administration to supervise and assess the implementation of compliance improvement plans and report to superior authorities in accordance with Clause 2 of this Article. The supervision and assessment shall be carried out on a regular basis and reported mid-term (in June each year), at the end of the implementation period (in December each year), and on an ad hoc basis upon request concerning the progress of implementation of compliance improvement plans.

CHAPTER III

RISK MANAGEMENT IN TAX ADMINISTRATION

Article 13. Classification of risk levels of taxpayers

1. Risk levels of taxpayers in professional tax administration operations shall be classified into one of the following levels:

a) High risk.

b) Medium risk.

c) Low risk.

2. Risk levels of taxpayers in each professional tax administration operation shall be classified on the basis of the indexes of risk assessment criteria appropriate to the characteristics of each professional tax administration operation, selected from the system of criteria specified in Appendices II and III to this Circular and combined with the results of the assessment of tax law compliance specified in Article 10 of this Circular.

3. Processing of results of classification of risk levels

The results of the classification of risk levels of taxpayers shall serve as the basis for the application of tax administration measures in each professional tax administration operation specified in Articles 14, 15, 16, 17, 18, 19 and 20 of this Circular.

Article 14. Application of risk management in tax registration management

Based on the list of taxpayers classified according to risk levels in tax registration management specified in Article 13 of this Circular, tax offices shall apply appropriate tax administration measures to handle and process dossiers or coordinate with business registration authorities in handling and processing dossiers in accordance with the laws on business registration and tax registration.

1. Changes in tax registration information resulting in a change in the directly managing tax office

a) For high-risk taxpayers: The tax office of the locality from which the taxpayer is relocated shall conduct examinations at the taxpayer’s head office in accordance with regulations.

b) For medium-risk taxpayers: The tax office of the locality to which the taxpayer is relocated shall place the taxpayer under supervision and request the taxpayer to provide additional explanations and documents when requested by the tax office.

c) For low-risk taxpayers: Not yet to carry out inspection and supervision; to assess and classify levels of tax law compliance by taxpayers and risk levels of taxpayers for the subsequent assessment period.

2. In case taxpayers notify suspension of their business activities

a) For high-risk taxpayers: To intensify the implementation of tax administration measures in accordance with regulations and appropriate to performance of tax obligations of taxpayers to promptly handle tax arrears, invoices and acts of violation (if any).

b) For medium-risk and low-risk taxpayers: To implement tax administration measures in accordance with regulations; to assess and classify levels of tax law compliance by taxpayers and risk levels of taxpayers for the subsequent assessment period.

3. In cases of invalidation of tax identification number

a) For high-risk taxpayers: To conduct tax examinations at offices of taxpayers in accordance with regulations.

b) For medium-risk and low-risk taxpayers: To apply measures to urge taxpayers to fulfill their tax obligations before dissolution, bankruptcy or termination of operation in accordance with regulations.

4. Restoration of tax identification numbers

a) For high-risk taxpayers: To conduct review and examination in accordance with regulations before restoring tax identification numbers of taxpayers.

b) For medium-risk and low-risk taxpayers: To restore tax identification numbers of taxpayers in accordance with regulations.

5. For other cases: To regularly review cases showing signs of high risks to determine the list of taxpayers of whom status of operation at head office of taxpayers need to be examined and verified.

Article 15. Application of risk management in the examination of tax declaration dossiers and other revenue dossiers at headquarter of tax offices

Based on the list of taxpayers classified according to risk levels in the examination of tax declaration dossiers and other revenue dossiers at headquarter of tax offices specified in Article 13 of this Circular, tax offices shall apply appropriate measures in handling and processing tax declaration dossiers and other revenue dossiers.

1. For high-risk taxpayers: To analyze dossiers, and make a list of taxpayers subjects to examination at headquarter of tax offices to submit plans on examination at headquarter of tax offices to heads of tax offices, and then examine tax declaration and other revenue dossiers at headquarter of tax offices under regulation;

2. For medium-risk and low-risk taxpayers: not yet to conduct examinations of tax declaration, other revenue dossiers at headquarter of tax offices; to assess and classify levels of tax law compliance by taxpayers and the risk levels of tax declaration and other revenue dossiers for the subsequent assessment period.

Article 16. Application of risk management in tax refund and other revenue refunds

Tax offices shall classify taxpayers having tax refund dossiers in accordance with the Law on Tax Administration No. 108/2025/QH15, its guiding documents and other relevant legal documents. For the classification of risk of taxpayers having tax refund dossiers, based on the classification results specified in Article 13 of this Circular and professional information at the time of issuance of tax refund decisions, tax offices shall apply appropriate measures in handling and processing tax refund dossiers as follows:

1. For taxpayers having value-added tax refund dossiers.

a) For high-risk taxpayers:

a.1) To conduct examination before tax refund, (except for the case specified at Point a.2 of this Clause).

a.2) In case a taxpayer’s tax refund dossier continues to be classified as high-risk due to the same risk sign or the same group of non-scoring risk criteria as the immediately preceding tax refund dossier, taxpayer’s tax refund dossier shall be subject to tax refund before examination provided that the examination of the immediately preceding tax refund dossier revealed no act of making false declaration leading to a deficit in the payable tax amount or an increase in the refundable tax amount, and the taxpayer does not fall into the category of high risk under another group of scoring criteria.

b) For medium-risk and low-risk taxpayers:

b.1) To conduct tax refund before examination: For the amount of tax claimed for refund in respect of which no risk has been identified.

Based on provisions of tax laws, tax refund dossiers of taxpayers and information in the database managed by tax offices, the tax compliance and risk management subsystem shall determine and specify the amount of tax in respect of which no risk has been identified in accordance with regulations.

b.2) For the amount of tax claimed for refund showing signs of risk, tax offices shall temporarily suspend the tax refund to collect information and conduct review and examination in accordance with regulations.

Within 02 years from the date of issuance of the tax refund decision, tax offices shall collect information and conduct review and examination of the amount of tax whose refund has been temporarily suspended, and shall process the amount of tax whose refund has been temporarily suspended after review and examination in accordance with regulations.

Based on the contents and scope requested by the tax office processing the tax refund, the tax office managing the taxpayer issuing invoices shall coordinate in exchanging information or conducting examinations at headquarter of tax offices or at offices of taxpayers in accordance with regulations so as to ensure that information is exchanged in a timely, complete and lawful manner.

b.3) The Taxation Department shall provide detailed guidance on: the amount of tax regarded as non-risk; the amount of tax regarded as at risk; the review and examination of the amount of tax whose refund has been temporarily suspended; and the processing of amount after review and examination.

2. Taxpayers having other tax refund, other revenue refund dossiers (hereinafter referred to as “other tax refund dossiers”).

a) For high-risk taxpayers: to conduct examination before tax refund.

b) For medium-risk and low-risk taxpayers: to conduct tax refund before examination.

3. Change of the classification form of tax refund dossiers

After the application has classified a tax refund dossier, if, during the processing of the tax refund dossier, the tax office processing the tax refund dossier obtains information through collection, and reviews, identifies that the taxpayer’s tax refund dossier shows signs of high risk, the tax office shall change the classification of the taxpayer’s tax refund dossier from the category subject to tax refund before examination to the category subject to examination before tax refund. The approval of change in classification shall be updated in the professional information system.

4. Post-tax refund examination

a) Within 05 years from the date of issuance of the tax refund decision, tax offices shall conduct post-tax refund examination according to the order of priority from higher to lower risk levels, specifically:

- For taxpayers having high-risk tax refund dossiers that are not subject to examination before tax refund as specified at Point a.2, Clause 1 of this Article: within 01 year from the date of issuance of the tax refund decision, tax offices shall conduct post-tax refund;

- For taxpayers having medium-risk tax refund dossiers: within 3 years from the date of issuance of the tax refund decision, tax offices shall conduct post-tax refund;

- For taxpayers having low-risk tax refund dossiers: within 5 years from the date of issuance of the tax refund decision, tax offices shall conduct post-tax refund.

Depending on the actual situation and tax administration requirements, tax offices may conduct post-tax refund examination before the above-mentioned time limits.

b) The Taxation Department shall provide detailed guidance on post-tax refund examination in combination with the examination of compliance with the tax laws in accordance with regulations.

Article 17. Application of risk management in examinations at offices of taxpayers

1. Principles for selecting cases for examinations at offices of taxpayers

a) Cases selected through the results of the analysis, assessment and classification of levels of tax law compliance by taxpayers and risk levels of taxpayers shall account for at least 90% of total cases subject to inspection and examination under annual plans.

b) Randomly selected cases account for at most 10% of total cases subject to inspection and examination under annual plans.

2. Selection of taxpayers to be included in plans on examination at offices of taxpayers

Based on the list of taxpayers classified according to the risk levels specified in Article 13 of this Circular, tax offices shall select cases subject to examination at offices of taxpayers as follows:

a) To select taxpayers to be included in annual plans on examination at offices of taxpayers based on the results of tax risk classification, in descending order of risk level.

b) The selection of taxpayers showing signs of risk for inclusion in plans on examination at offices of taxpayers shall not overlap, in terms of subject matter, scope or timing, with other tax examination activities or other inspection and examination activities conducted in accordance with the Law on Tax Administration No. 108/2025/QH15, its guiding documents, and other relevant legal documents.

c) Where, in the course of tax administration, tax offices obtain reliable information indicating that a taxpayer’s risk level has decreased to the low-risk level, or where there are grounds for determining that the taxpayer’s risk level is low and taxpayer has not yet been included in the annual examination plan, the tax office shall decide not to include such taxpayer in the annual examination plan and shall select another taxpayer in accordance with regulations for inclusion in the annual examination plan. Where, during tax administration, information is collected and verified showing that a taxpayer has signs of high risk, the tax office shall supplement taxpayer to the annual examination plan. Tax offices shall take responsibility for their decisions to make changes.

d) The formulation of, and the competence to approve plans on examination at offices of taxpayers; and the lists of cases to be added to, or adjustments to, plans on examination at offices of taxpayers under this Article shall comply with the Law on Tax Administration No. 108/2025/QH15, its guiding documents, and other relevant legal documents.

3. Tax offices shall, based on the results of risk analysis generated by information technology applications or risk identified through professional analysis, information obtained during tax administration, determine the cases to be examined and the contents, scope and duration of tax examinations.

Article 18. Application of risk management in the management of tax arrears, other revenues, and enforcement of tax administrative decisions

Based on the list of taxpayers classified according to risk levels in the management of tax arrears, other revenues, and the enforcement of tax administrative decisions as prescribed in Article 13 of this Circular, tax offices shall manage tax arrears and carry out enforcement measures in accordance with the Law on Tax Administration No. 108/2025/QH15 and guiding documents, taking into account risk levels so as to prioritize handling, allocating resources, and strengthening debt recovery measures in accordance with the following principles:

1. For high-risk taxpayers: To increase the frequency of monitoring during each month, intensify debt recovery measures, and conduct direct meetings with taxpayers to promptly recover tax arrears payable to the state budget, including applying the measure of temporary exit suspension; selecting and applying one or more appropriate measures for the enforcement of tax administrative decisions to ensure the timely and full recovery of tax arrears into the state budget; and publicly disclosing information on outstanding tax debts.

2. For medium-risk taxpayers: To conduct monthly monitoring, implement reminder, advisory and taxpayer support measures to facilitate the performance of tax payment obligations, apply temporary exit suspension according to the prescribed thresholds, publicly disclose tax debt information in accordance with Point a, Clause 3, Article 7 of the Law on Tax Administration No. 108/2025/QH15, and apply measures for the enforcement of tax administrative decisions in accordance with the procedures prescribed by the Law on Tax Administration No. 108/2025/QH15 and guiding documents.

3. For low-risk taxpayers: To supervise, remind, advise and assist taxpayers in fulfilling their tax obligations, to be considered that the measures of temporary exit suspension and enforcement of tax administrative decisions may be not apply in accordance with the Law on Tax Administration No. 108/2025/QH15 and guiding documents.

Article 19. Application of risk management in the management of tax exemption and tax reduction

Tax offices shall manage tax exemption and tax reduction dossiers in accordance with the Law on Tax Administration No. 108/2025/QH15 and guiding documents; while applying risk management in the course of processing tax exemption and tax reduction dossiers. Based on the results of the classification of risk levels specified in Article 13 of this Circular, tax offices shall apply measures corresponding to each risk level as follows:

1. For high-risk taxpayers: To conduct examinations at offices of taxpayers in accordance with regulations.

2. For medium-risk and low-risk taxpayers: To receive and process tax exemption and tax reduction dossiers in accordance with the prescribed order and procedures; concurrently, to conduct monitoring and examinations after processing tax exemption and tax reduction dossiers according to plans or where signs of risk arise.

Article 20. Application of risk management in management of invoices and documents, and other professional operations in tax administration

1. Application of risk management in management of invoices and documents

Based on the results of risk analysis according to each set of criteria indexes for classifying risk levels of taxpayers in the management of invoices and documents, tax offices shall apply the following management measures:

a) For high-risk taxpayers: Tax offices shall apply appropriate management measures, including refusing the registration for the use of electronic invoices, suspending the use of electronic invoices, or applying other invoice management measures in accordance with regulations.

b) For medium-risk and low-risk taxpayers: To select suitable subjects for review, examination and handling in accordance with regulations; to strengthen the monitoring and analysis of invoice and document data in order to promptly detect and prevent emerging risks; to provide support and guidance to taxpayers to ensure proper compliance with the laws on invoices and documents.

The Taxation Department shall provide detailed guidance on methods of selection of suitable subjects appropriate to the tax administration requirements of each locality and each period.

2. Application of risk management in other professional operations

Based on the risk levels in other professional operations and professional information, tax offices shall decide on the application of appropriate professional measures in accordance with their functions and duties.

Article 21. Examination and assessment of application of risk management in management of tax registration

1. Contents of examination and assessment

The examination and assessment of application of risk management in management of tax registration shall focus on the following contents:

a) Quality of the application of professional risk management measures and techniques;

b) Efficacy and effectiveness of the application of risk management in professional tax administration operations;

c) Organization and results of implementation of examination or inspection decisions or other professional measures on the basis of application of risk management;

d) Effectiveness of the system of criteria and indexes used for the assessment and classification of levels of tax law compliance by taxpayers and risk levels of taxpayers.

2. Measures for examination and assessment

The examination and assessment shall be carried out through the following measures:

a) To summarize and analyze information and statistical reports of tax offices at all levels and units under the Taxation Department concerning the application of risk management;

b) To collect, analyze and summarize information and data on the results of the application of risk management in professional tax administration operations;

c) To form working teams to carry out examination of the application of risk management at tax offices at all levels in accordance with regulations.

3. Responsibilities of units

The Director General of the Taxation Department shall assign relevant units, units assigned to perform the tasks of compliance management, risk management shall examine, assess the implementation of risk management in tax administration and report to superior authorities in accordance with Clause 2 of this Article. The assessment shall be conducted on a regular basis, reported periodically (every six months and annually), and conducted on an ad hoc basis as required by operational needs.

CHAPTER IV

IMPLEMENTATION PROVISIONS

Article 22. Implementation responsibilities

1. The Director General of the Taxation Department, based on the provisions of this Circular, shall promulgate:

a) Sets of criteria indexes specified in Articles 10 and 13 of this Circular to meet tax administration requirements in each period; periodically on an annual basis or upon request arising from tax administration, review, amend and supplement criteria indexes to ensure that they remain updated and appropriate to practical circumstances;

b) Detailed guidance on the responsibilities of tax offices at all levels and tax officers, and on measures for collecting and processing information for compliance management and risk management in tax administration; scores, weighted scores and professional measures and techniques to manage risks in tax administration;

c) Processes, regulations, provisions and guidance on application of compliance management and risk management in tax administration.

2. The unit assigned to perform compliance management and risk management tasks in tax administration shall act as the focal unit and take primary responsibility for:

a) Managing and coordinating the operation of the tax compliance and risk management subsystem and information systems and databases serving compliance management and risk management in accordance with its assigned responsibilities;

b) Organizing the implementation of, providing professional guidance on, and examining the collection and processing of information for compliance management and risk management in tax administration; professional measures, technical measures, and the application of compliance management and risk management in professional tax administration operations;

c) Managing the sets of criteria indexes promulgated by the Director General of the Taxation Department on the tax compliance and risk management subsystem and relevant information systems under Point a, Clause 1 of this Article; monitoring, assessing, adjusting and supplementing such criteria indexes to meet tax administration requirements in each period.

3. State agencies coordinating in state tax administration; taxpayers; organizations and individuals related to tax administration activities; provincial/municipal tax offices, grassroots tax offices, divisions, the Large Enterprise Tax Sub-department, the E-commerce Tax Sub-department under the Taxation Department; and tax officers shall implement fully and properly the provisions on the application of compliance management and risk management in tax administration prescribed in this Circular and other relevant legal documents.

Article 23. Effect

1. This Circular takes effect on July 01, 2026.

2. This Circular replaces the Minister of Finance’s Circular No. 31/2021/TT-BTC of May 17, 2021, providing the application of risk management in tax administration.

3. In case legal documents referred to in this Circular are amended, supplemented or replaced by newly promulgated legal documents, the latter shall prevail./.