Decree 310/2025/ND-CP amending Decree 125/2020/ND-CP on sanctioning administrative violations related to taxes and invoices

DECREE

Amending and supplementing a number of articles of the Government’s Decree No. 125/2020/ND-CP dated October 19, 2020, on sanctioning of administrative violations related to taxes and invoices

Pursuant to the Law on Organization of the Government No. 63/2025/QH15;

Pursuant to Law on Handling of Administrative Violations No. 15/2012/QH13, which was amended and supplemented under Law No. 54/2014/QH13, Law No. 18/2017/QH14, Law No. 67/2020/QH14, Law No. 09/2022/QH15, Law No. 11/2022/QH14, Law No. 56/2024/QH14 and Law No. 88/2025/QH14;

Pursuant to the Law on Tax Administration No. 38/2019/QH14, which was amended and supplemented under Law No. 56/2024/QH15;

At the proposal of the Minister of Finance;

The Government hereby promulgates the Decree amending and supplementing a number of articles of the Government’s Decree No. 125/2020/ND-CP dated October 19, 2020, on sanctioning of administrative violations related to taxes and invoices.

Article 1. Amending and supplementing a number of articles of the Government’s Decree No. 125/2020/ND-CP dated October 19, 2020, on sanctioning of administrative violations related to taxes and invoices

1. To amend and supplement Clause 1; and to add Clause 10 to Article 2 as follows:

a) To amend and supplement Clause 1 as follows:

“1. Administrative violations related to taxes mean faulty acts committed by organizations or individuals in violation of the law on tax administration, tax laws, and other revenues under the state budget managed and collected by tax administration agencies (land use levy; land rentals and water surface rentals; charge for the grant of the mineral exploitation right; charge for the grant of the right to exploitation of water resources; remaining after-tax profit after setting up funds of enterprises with 100% state-owned charter capital; dividends and profits distributed for the state capital invested in joint-stock companies and limited liability companies with two or more members; revenues as prescribed by the law on management and use of state capital invested in enterprises) which do not constitute crimes and, under law, must be administratively sanctioned.”.

b) To add Clause 10 after Clause 9 as follows:

“10. Force majeure events include: natural disasters, catastrophes, epidemics, fires, unexpected accidents, war, riots, strikes, or events occurring objectively, unforeseeable, and the taxpayer is unable to remedy them despite having applied all necessary and possible measures.”.

2. To amend and supplement Point a, Clause 1, Article 3 as follows:

“a) Taxpayers committing administrative violations related to taxes and invoices.

In case where the taxpayer authorizes another organization or individual to fulfill tax liability but the law on taxes and tax administration stipulates that the performance on behalf of the taxpayer falls under the authorized party's obligations and responsibilities, if the authorized party commits acts of administrative violation specified in this Decree, the authorized organization or individual shall be sanctioned according to this Decree.

In case according to the law on taxes and tax administration, an organization or individual that is obliged to carry out tax registration, declaration or payment on behalf of the taxpayer commits administrative violations specified in this Decree, such organization or individual shall be administratively sanctioned for tax-related violations in accordance with this Decree.

In case where, under the Global Anti-Base Erosion Model Rules, a constituent entity responsible for declaration has the obligation to make tax registration, submit the tax declaration dossier, and pay the top-up tax, and the constituent entity assigned by the Group to send the notification of the constituent entity responsible for declaration and the list of constituent entities subject to the application of Resolution No. 107/2023/QH15 commits any administrative violation under this Decree, such entity shall be sanctioned in accordance with this Decree.”.

3. To amend and supplement Points a, b, c, Clause 3; and to add Points dd, e and g to Clause 3, Article 5 as follows:

a) To amend Points a, b and c, Clause 3 as follows:

“a) Where, on the same day, the taxpayer makes incorrect declarations in one or more indicators on tax dossiers, the act of incorrect declaration falling under tax procedure sanctioning shall be sanctioned for only one act of incorrect declaration of an indicator on the tax dossier, which is subject to the highest monetary fine bracket among all acts committed in accordance with this Decree;

b) Where, on the same day, the taxpayer is late in submitting multiple tax declaration dossiers of the same tax type, the taxpayer shall be sanctioned for only one act of late submission of a tax declaration dossier, which is subject to the highest monetary fine bracket among all acts committed in accordance with this Decree.

Where among the late-submitted tax declaration dossiers there is a dossier whose late submission falls under tax evasion, such dossier shall be separated for sanctioning for the act of tax evasion;

c) Where, on the same day, the taxpayer is late in submitting multiple notifications or reports of the same type regarding invoices, the taxpayer shall be sanctioned for one act of late submission of an invoice-related notification or report, which is subject to the highest monetary fine bracket among all acts committed in accordance with this Decree;”;

b) To add Points dd, e and g after Point d, Clause 3 as follows:

“dd) Where the taxpayer commits multiple acts of issuing invoices at incorrect time, and such violations remain within the statute of limitations for sanctioning and are sanctioned in a single administrative violation case, the taxpayer shall be sanctioned for only one act of issuing invoices at incorrect time, with the monetary fine bracket corresponding to the number of invoices issued at incorrect time as prescribed in Clause 2, Article 24 of this Decree;

e) Where the taxpayer commits multiple acts of failing to issue invoices, and such violations remain within the statute of limitations for sanctioning and are sanctioned in a single administrative violation case, the taxpayer shall be sanctioned for only one act of failing to issue invoices, with the monetary fine bracket corresponding to the number of invoices not issued at the correct time as prescribed in Clause 3, Article 24 of this Decree;

g) Where the taxpayer makes incorrect declarations in multiple indicators on a single tax dossier falling under the case subject to sanctioning for tax procedures, the taxpayer shall be sanctioned for only one act of incorrect declaration of an indicator on the tax dossier, with the highest monetary fine bracket among all acts committed in accordance with this Decree.

Where the taxpayer makes incorrect declarations in multiple indicators on a single tax dossier that simultaneously falls under the case subject to sanctioning for tax procedures and the case subject to sanctioning under Article 16 or Article 17 of this Decree, the taxpayer shall be sanctioned for only one act under Article 16 or Article 17 of this Decree.”.

4. To amend and supplement Clause 2, Article 6 as follows:

“2. Administrative violations on a large scale as prescribed in Point l, Clause 1, Article 10 of the Law on Handling of Administrative Violations are determined in the following cases:

a) Committing an administrative violation related to invoices with a quantity of 10 invoice numbers or more, for the acts prescribed in Clause 2, Article 22, Article 26, and Article 27 of this Decree;

b) Committing an act of tax evasion prescribed in Article 17 of this Decree with the evaded tax amount of VND 100,000,000 or more, for cases in which the violation dossier is transferred for administrative sanctioning in accordance with Article 63 of the Law on Handling of Administrative Violations.”.

5. To amend and supplement Point b, Clause 1; to amend and supplement Points d and e, Clause 3; to amend and supplement Point d, Clause 4, Article 7 as follows:

a) To amend and supplement Point b, Clause 1 as follows:

“b) Fine

The maximum fine for an administrative violation related to tax procedures and invoices shall comply with the law on handling of administrative violations.

A fine equal to 20% of the deficit tax amount or the exemptible, reducible or refundable tax amount that is higher than prescribed level shall be imposed for the act of incorrectly declaring, leading to a sufficiency in the payable tax amount or an increase in the exemptible, reducible or refundable tax amount.

A fine from 01 to 03 times of the evaded tax amount shall be imposed for the act of tax evasion.

A fine corresponding to the amount not credited to the state budget account shall be imposed for violations prescribed in Clause 1, Article 18 of this Decree.”;

b) To amend and supplement Points d and e, Clause 3 as follows:

“d) Forcible notification of the constituent entity responsible for declaration and the list of constituent entities subject to the application of Resolution No. 107/2023/QH15.

e) Forcible destruction of invoices.”;

c) To amend and supplement Point d, Clause 4 as follows:

“d) A specific fine for an act of violation related to invoice or tax procedure and act of violation specified in Article 19 of this Decree shall be the average fine level of the fine bracket for such act of violation. If there is one extenuating circumstance, a reduction of 10% of the average fine of the fine bracket shall be applied; if there is one aggravating circumstance, an increase of 10% of the average fine of the fine bracket shall be applied. In case where there are 02 or more extenuating circumstances, the minimum level of the fine bracket shall be applied; if there are 02 or more aggravating circumstances, the maximum level of the fine bracket shall be applied.”.

6. To amend and supplement Points c and d, Clause 1; to amend and supplement Points a and b, Clause 2, Article 8 as follows:

a) To amend and supplement Points c and d, Clause 1 as follows:

“c) The in-progress administrative violations related to invoices that are violations specified in Clause 3, Article 24; Point b, Clause 3, Article 25; Point b, Clause 2 and Point b, Clause 3, Article 27; Point b, Clause 5, Article 29; and Point b, Clause 3, Article 30 of this Decree.

d) Administrative violations related to invoices other than those prescribed at Point c of this Clause are completed administrative violations. The time when the violation is completed is the date on which the act of violation is committed.

For acts of losing, burning, or damaging invoices, if the date of loss, burning, or damage cannot be determined, the time when the violation is completed is the date on which the invoice is detected to be lost, burned, or damaged.

For violations concerning the deadline for notification or reporting on invoices prescribed in Clause 1, Clause 2, and Point a, Clause 3, Article 25; Clause 1, Point a, Clause 2, Clause 3, Clause 4, and Point a, Clause 5, Article 29 of this Decree, the time when the violation is completed is the date on which the taxpayer submits the notification or report on invoices.”;

b) To amend and supplement Points a and b, Clause 2 as follows:

“a) The statute of limitations for sanctioning acts of violation of tax procedures is 02 years from the date the violation is committed.

The date on which the administrative violation related to tax procedures is committed is the day succeeding the deadline for tax procedure according to the law on tax administration, except for the following cases:

For the acts of violation specified in Clause 1, Points a and b, Clause 2, Clause 3, and Point a, Clause 4, Article 10; Clauses 1, 2, 3 4, and Point a, Clause 5, Article 11; Clauses 1, 2, 3, and Points a and b, Clause 4, Clause 5, Article 13 of this Decree, the date of committing violations for the calculation of the statute of limitations is the date when the taxpayer carries out tax registration or notifies to the tax agency or submits the tax declaration dossier.

For acts prescribed at Points c and d, Clause 2, and Point b, Clause 4, Article 10; Point b, Clause 5, Article 11; Points c and d, Clause 4, Article 13 of this Decree, that are in-progress administrative violations related to taxes, the date of committing the violation for calculating the statute of limitations is the date on which the competent person on duty detects the violation.

b) The statute of limitations for the act of tax evasion that is not serious enough for penal liability examination, the act of incorrectly declaring, leading to an sufficiency in the payable tax amount or an increase in the exemptible, reducible or refundable tax amount, is 05 years from the day on which the violation is committed.

The date of committing an act of incorrect declaration leading to an sufficiency in the payable tax amount or an increase in the exemptible, reducible or refundable tax amount, or an act of tax evasion (except for the act prescribed at Point a, Clause 1, Article 17 of this Decree) is the day following the last day of the deadline for submission of the tax declaration dossier for the tax period in which the taxpayer under-declared or evaded tax, or the day following the date on which the competent agency issues a decision on tax exemption, tax reduction, or tax refund.

For acts of failure to submit tax registration dossiers or failure to submit tax declaration dossiers prescribed at Point a, Clause 1, Article 17 of this Decree, that are in-progress administrative violations related to taxes, the date of committing the violation for calculating the statute of limitations is the date on which the competent person on duty detects the violation. For acts of submitting tax declaration dossiers more than 90 days late prescribed at Point a, Clause 1, Article 17 of this Decree, the date of committing the violation for calculating the statute of limitations is the date on which the taxpayer submits the tax declaration dossier.”.

7. To amend and supplement Clause 3, Article 9 as follows:

“3. No administrative sanction for tax-related violations shall be imposed in cases of incorrect declaration where the taxpayer has made an additional tax declaration dossier in accordance with the law on tax administration and has voluntarily paid in full the payable tax amount before the tax agency announces a tax inspection decision, before another competent agency announces an inspection or examination decision at the taxpayer’s office, or before the tax agency detects the violation without conducting an inspection at the taxpayer’s office, or before another competent agency detects the violation.”.

8. To amend the title of Article 10; to amend and supplement Clause 1; and to add Point d to Clause 2, and Clause 5 to Article 10 as follows:

a) To amend the title of Article 10 as follows:

“Article 10. Sanctioning of violations concerning the time limit for tax registration; notification of temporary business suspension; notification of resumption of business operation before the notified time limit; notification of the constituent entity responsible for declaration and the list of constituent entities subject to the application of Resolution No. 107/2023/QH15”;

b) To amend and supplement Clause 1 as follows:

“1. A warning shall be imposed for any of the following acts of violation:

a) Tax registration; notification of temporary business suspension; notification of resumption of business operation before the notified time limit made past the prescribed deadline from 01 day to 10 days and having an extenuating circumstance;

b) Notification of the constituent entity responsible for declaration and the list of constituent entities subject to the application of Resolution No. 107/2023/QH15 made past the prescribed deadline.”;

c) To add Point d after Point c, Clause 2 as follows:

“d) Failure to notify the constituent entity responsible for declaration and the list of constituent entities subject to the application of Resolution No. 107/2023/QH15.”;

d) To add Clause 5 after Clause 4 as follows:

“5. Remedial measures: Forcible notification of the constituent entity responsible for declaration and the list of constituent entities subject to the application of Resolution No. 107/2023/QH15, for violations specified at Point d, Clause 2 of this Article.”.

9. To amend and supplement Clause 6, Article 11 as follows:

“6. This Article shall not apply to the following cases:

a) Individuals who do not conduct business and have been issued personal income tax identification numbers but fail to timely update information according to their identity cards or electronic identity cards;

b) Income-paying agencies that fail to timely notify changes in information when personal income taxpayers who authorize such agencies to make personal income tax finalization have changes in information according to their identity cards or electronic identity cards;

c) Failure to notify or late notification of changes in information on tax registration dossiers concerning the taxpayer’s address beyond the prescribed time limit due to changes in administrative boundaries under a Resolution of the National Assembly Standing Committee or the National Assembly.”.

10. To amend and supplement Clause 5; to amend Point a, Clause 6, Article 13 as follows:

a) To amend and supplement Clause 5 as follows:

“5. A fine from VND 15,000,000 to VND 25,000,000 shall be imposed for acts of submitting tax declaration dossiers more than 90 days past the deadline for submission, where tax liability arises and the taxpayer has fully paid the tax amount and the late payment interest to the state budget before the tax agency announces a tax inspection decision, before another competent agency announces an inspection or examination decision, or before the tax agency prepares a record of the act of late submission of the tax declaration dossier.

Where the fine determined under this Clause exceeds the tax amount arising under the tax declaration dossier, the maximum fine for this case shall be equal to the payable tax amount arising under the tax declaration dossier or the total payable tax amounts arising under the tax declaration dossiers under the case prescribed at Point b, Clause 3, Article 5 of this Decree, but shall not be lower than the average level of the fine bracket prescribed in Clause 4 of this Article.”;

b) To amend Point a, Clause 6 as follows:

“a) Forcible full payment of the late payment interest into the state budget for violations prescribed in Clauses 1, 2, 3, and Clause 4 of this Article in case where the taxpayer’s late submission of the tax declaration dossier results in late payment of tax.”.

11. To amend Point c, Clause 1, Article 16 as follows:

c) Incorrectly declaring tax leading to a decrease in payable tax amounts or an increase in exemptible, reducible or refundable tax amounts, has been determined as a tax evasion by the agency competent to make administrative violation records, but the taxpayer commits administrative violations of tax evasion for the first time, and has made additional declarations and fully paid the tax amount to the state budget before the time the competent agency issues the sanctioning decision and the tax agency already made a written record to determine that incorrect declaration leads to insufficiency of tax amount;”.

12. To amend and supplement Article 19 as follows:

“Article 19. Sanctioning of tax-related administrative violations committed by relevant organizations and individuals

1. A fine from VND 2,000,000 to VND 6,000,000 shall be imposed for the act of providing information or documents related to the determination of tax obligations or the taxpayer’s accounts, as prescribed by law or at the request of the tax agency, 05 days or more past the prescribed time limit.

2. A fine of between VND 6,000,000 and VND 10,000,000 shall be imposed for any of the following violations:

a) Providing inaccurate information related to assets, rights, or obligations regarding the assets of the taxpayer under their management; or providing information or documents related to the determination of the taxpayer’s tax obligations as prescribed by law or at the request of the tax agency;

b) Providing inaccurate information related to the taxpayer’s accounts at credit institutions, the State Treasury, or foreign bank branches as prescribed by law or at the request of the tax agency;

c) Providing inaccurate information related to the taxpayer’s salary, wages, or income under their management as prescribed by law or at the request of the tax agency.

3. A fine from VND 10,000,000 to VND 16,000,000 shall be imposed for any of the following violations:

a) Failing to provide information related to assets, rights, or obligations regarding the assets of the taxpayer under their management; information or documents related to the determination of the taxpayer’s tax obligations as prescribed by law or at the request of the tax agency;

b) Failing to provide information related to the taxpayer’s accounts at credit institutions, the State Treasury, or foreign bank branches as prescribed by law or at the request of the tax agency;

c) Failing to provide inaccurate information related to the taxpayer’s salary, wages, or income under their management as prescribed by law or at the request of the tax agency;

d) Colluding with or covering up taxpayers that evade taxes, or failing to comply with administrative tax enforcement decisions, except for the act of failure to remit funds from the taxpayer’s account prescribed in Article 18 of this Decree.

4. Remedial measures: Forcible provision of sufficient and accurate information, for violations specified in Clause 2, and Points a, b and c, Clause 3 of this Article.”.

13. To amend Clause 2, Article 22 as follows:

“2. A fine from VND 20,000,000 to VND 50,000,000 shall be imposed for the act of giving or selling invoices.”.

14. To amend and supplement Clauses 2, 3 and 6, Article 24 as follows:

a) To amend and supplement Clause 2 as follows:

“2. Acts of issuing invoices at incorrect time as prescribed by law shall be sanctioned as follows:

a) A warning shall be imposed for the act of issuing invoices at incorrect time for goods or services used for promotion, advertising, or as samples; for goods or services used for giving, gifting, donating, exchanging, or paying wages to employees and for internal consumption (except for goods internally circulated for continued production); and for issuing goods in the form of lending, borrowing, or returning goods involving 01 invoice number;

b) A fine from VND 500,000 to VND 1,500,000 shall be imposed for the act of issuing invoices at incorrect time for goods or services used for promotion, advertising, or as samples; for goods or services used for giving, gifting, donating, exchanging, or paying wages to employees and for internal consumption (except for goods internally circulated for continued production); issuing goods in the form of lending, borrowing, or returning goods involving 02 to fewer than 10 invoice numbers, and issuing invoices at incorrect time when selling goods or providing services involving 01 invoice number;

c) A fine from VND 2,000,000 to VND 5,000,000 shall be imposed for the act of issuing invoices at incorrect time for goods or services used for promotion, advertising, or as samples; for goods or services used for giving, gifting, donating, exchanging, or paying wages to employees and for internal consumption (except for goods internally circulated for continued production); issuing goods in the form of lending, borrowing, or returning goods involving 10 to fewer than 50 invoice numbers, and issuing invoices at incorrect time when selling goods or providing services involving from 2 to fewer than 10 invoice numbers;

d) A fine from VND 5,000,000 to VND 15,000,000 shall be imposed for the act of issuing invoices at incorrect time for goods or services used for promotion, advertising, or as samples; for goods or services used for giving, gifting, donating, exchanging, or paying wages to employees and for internal consumption (except for goods internally circulated for continued production); issuing goods in the form of lending, borrowing, or returning goods involving 50 to fewer than 100 invoice numbers, and issuing invoices at incorrect time when selling goods or providing services involving from 10 to fewer than 20 invoice numbers;

dd) A fine from VND 15,000,000 to VND 30,000,000 shall be imposed for the act of issuing invoices at incorrect time for goods or services used for promotion, advertising, or as samples; for goods or services used for giving, gifting, donating, exchanging, or paying wages to employees and for internal consumption (except for goods internally circulated for continued production); issuing goods in the form of lending, borrowing, or returning goods involving 100 or more invoice numbers, and issuing invoices at incorrect time when selling goods or providing services involving from 20 to fewer than 50 invoice numbers;

e) A fine from VND 30,000,000 to VND 50,000,000 shall be imposed for the act of issuing invoices at an incorrect time when selling goods or providing services involving from 50 to fewer than 100 invoice numbers;

g) A fine from VND 50,000,000 to VND 70,000,000 shall be imposed for the act of issuing invoices at an incorrect time when selling goods or providing services involving 100 or more invoice numbers.”;

b) To amend and supplement Clause 3 as follows:

“3. Acts of failing to issue invoices as prescribed shall be sanctioned as follows:

a) A warning shall be imposed for the act of failing to issue invoices for goods or services used for promotion, advertising, or as samples; for goods or services used for giving, gifting, donating, exchanging, or paying wages to employees and for internal consumption (except for goods internally circulated for continued production); and for issuing goods in the form of lending, borrowing, or returning goods involving 01 invoice number;

b) A fine from VND 1,000,000 to VND 2,000,000 shall be imposed for the act of failing to issue invoices for goods or services used for promotion, advertising, or as samples; for goods or services used for giving, gifting, donating, exchanging, or paying wages to employees and for internal consumption (except for goods internally circulated for continued production); issuing goods in the form of lending, borrowing, or returning goods involving 02 to fewer than 10 invoice numbers, and failing to issue invoices when selling goods or providing services involving 01 invoice number as prescribed;

c) A fine from VND 2,000,000 to VND 10,000,000 shall be imposed for the act of failing to issue invoices for goods or services used for promotion, advertising, or as samples; for goods or services used for giving, gifting, donating, exchanging, or paying wages to employees and for internal consumption (except for goods internally circulated for continued production); issuing goods in the form of lending, borrowing, or returning goods involving 10 to fewer than 50 invoice numbers, and failing to issue invoices when selling goods or providing services involving from 2 to fewer than 10 invoice number as prescribed;

d) A fine from VND 10,000,000 to VND 30,000,000 shall be imposed for the act of failing to issue invoices for goods or services used for promotion, advertising, or as samples; for goods or services used for giving, gifting, donating, exchanging, or paying wages to employees and for internal consumption (except for goods internally circulated for continued production); issuing goods in the form of lending, borrowing, or returning goods involving 50 to fewer than 100 invoice numbers, and failing to issue invoices when selling goods or providing services involving from 10 to fewer than 20 invoice number as prescribed;

dd) A fine from VND 30,000,000 to VND 50,000,000 shall be imposed for the act of failing to issue invoices for goods or services used for promotion, advertising, or as samples; for goods or services used for giving, gifting, donating, exchanging, or paying wages to employees and for internal consumption (except for goods internally circulated for continued production); issuing goods in the form of lending, borrowing, or returning goods involving 100 or more invoice numbers, and failing to issue invoices when selling goods or providing services involving from 20 to fewer than 50 invoice number as prescribed;

e) A fine from VND 60,000,000 to VND 80,000,000 shall be imposed for the act of failing to issue invoices when selling goods or providing services involving 50 or more invoice numbers as prescribed.”;

c) To amend and supplement Clause 6 as follows:

“6. Remedial measures: a) Forcible issuance of invoices according to regulations, for violations prescribed in Clause 3 and Point d, Clause 4 of this Article.”.

15. To amend the title of Article 25 as follows:

“Article 25. Sanctioning of violations of regulations on reporting the loss, burning or damage of invoices purchased from tax agencies but not yet issued”.

16. To amend Point a, Clause 3, Article 26 as follows:

“a) Losing, burning, or damaging invoices purchased from the tax agency but not yet issued;”.

17. To amend Article 27 as follows:

“Article 27. Sanctioning of violations of regulations on invoice destruction

1. A warning shall be imposed for the acts of destroying invoices beyond the prescribed period for destruction from 01 to 05 working days, under extenuating circumstances.

2. A fine from VND 2,000,000 to VND 4,000,000 shall be imposed for any of the following violations:

a) Destroying printed invoices purchased from the tax agency that are no longer in use or no longer valid for use as notified by the tax agency, in contravention of regulations;

b) Failing to destroy printed invoices purchased from the tax agency that are no longer in use or no longer valid for use as notified by the tax agency;

c) Destroying invoices beyond the prescribed period for destruction from 01 to 10 working days, except for the case prescribed in Clause 1 of this Article.

3. A fine from VND 4,000,000 to VND 8,000,000 shall be imposed for any of the following violations:

a) Destroying invoices beyond the prescribed period for destruction 11 working days or more;

b) Failing to destroy invoices as prescribed by law;

c) Destroying invoices in contravention of the order and procedures prescribed by law;

d) Destroying invoices not subject to destruction as prescribed.

4. Remedial measures: Forcible destruction of invoices, for violations specified at Point b, Clause 2 and Point b, Clause 3 of this Article.”.

18. To amend and supplement Article 31 as follows:

“Article 31. Sanctioning of violations of regulations on invoice service provision

A fine from VND 4,000,000 to VND 8,000,000 shall be imposed for the act of providing solutions for the creation, connection for receipt, transmission, receipt, storage, and processing of e-invoice data that fail to ensure the principles prescribed by the law on invoices.”.

19. To amend and supplement Clause 1, Clause 3, Clause 4 and Clause 5, Article 32 as follows:

a) To amend and supplement Clause 1 as follows:

“1. Tax officers on duty may:

a) Impose warning;

b) Impose a fine of up to VND 20,000,000 for the violations prescribed in Articles 10, 11, 12, Clauses 1, 2, 3, and 4, Article 13, and Articles 14, 15, and 19, Chapter II of this Decree;

c) Impose a fine of up to VND 10,000,000, for violations prescribed at Points b and c, Clause 2, Points b and c, Clause 3, Clause 4, Article 24, and Articles 25, 26, 27, Clauses 2, 3, and 4, Article 29, Clauses 1 and 2, Article 30, and Article 31, Chapter III of this Decree.”;

b) To amend and supplement Clause 3 as follows:

“3. Heads of grassroots-level tax agencies may:

a) Impose warning;

b) Impose a fine of up to VND 100,000,000, for violations prescribed in Articles 10, 11, 12, 13, 14, 15, and 19, Chapter II of this Decree;

c) Impose fines, for violations prescribed in Articles 16, 17, and 18 of this Decree;

d) Impose a fine of up to VND 50,000,000, for violations prescribed in Article 22; Points b, c, d, dd and e, Clause 2; Points b, c, d and dd, Clause 3, Clause 4, Article 24, and Articles 25, 26, 27, 28, 29, 30, and 31, Chapter III of this Decree;

dd) Apply remedial measures specified in this Decree.”;

c) To amend and supplement Clause 4 as follows:

“4. Directors of Tax Sub-Departments and heads of provincial-level Tax Offices may:

a) Impose warning;

b) Impose a fine of up to VND 160,000,000, for violations prescribed in Article 10, 11, 12, 13, 14, 15 and 19, Chapter II of this Decree;

c) Impose fines, for violations prescribed in Articles 16, 17, and 18 of this Decree;

d) Impose a fine of up to VND 80,000,000, for violations prescribed in Chapter III of this Decree;

dd) Apply remedial measures specified in this Decree.”;

d) To amend and supplement Clause 5 as follows:

“5. The Director of the Department of Taxation may:

a) Impose warning;

b) Impose a fine of up to VND 200,000,000, for violations prescribed in Articles 10, 11, 12, 13, 14, 15, and 19, Chapter II of this Decree;

c) Impose fines, for violations prescribed in Articles 16, 17, and 18 of this Decree;

d) Impose a fine of up to VND 100,000,000, for violations prescribed in Chapter III of this Decree;

dd) Apply remedial measures specified in this Decree.”.

20. To amend Clause 1, Article 33 as follows:

“1. Chairpersons of commune-level People’s Committees may:

a) Impose warning;

b) Impose a fine of up to VND 100,000,000, for violations prescribed in Articles 10, 11, 12, 13, 14, 15, and 19, Chapter II of this Decree;

c) Impose a fine of up to VND 50,000,000, for violations prescribed in Article 22; Points b, c, d, dd and e, Clause 2; Points b, c, d and dd, Clause 3, Clause 4, Article 24, and Articles 25, 26, 27, 28, 29, 30, and 31, Chapter III of this Decree;

d) Apply the remedial measures specified in Articles 10, 11, 12, 13, 14, 15, and 19, Chapter II and Chapter III of this Decree.”.

21. To amend and supplement Point b, Clause 2, Article 36 as follows:

“b) Making electronic records of administrative violations

In case where taxpayers are late in submitting tax registration dossiers, changing tax registration information, submitting tax declaration dossiers or tax finalization dossiers, or late in submitting electronic notifications or reports on invoices, within 03 working days from the date on which the tax agency sends the notice of receipt of the electronic tax registration dossier, electronic dossier of change of tax registration information, or the notice of acceptance of the electronic tax declaration or tax finalization dossier, the tax agency shall prepare and send 01 electronic administrative violation record to the taxpayer via the tax administration agency's portal, including cases where the taxpayer submits multiple tax dossiers.

Electronic administrative violation records shall be prepared and transmitted in compliance with the requirements for electronic transactions in the tax sector and shall serve as the basis for the tax agency to issue decisions on sanctioning administrative violations.

Electronic administrative violation records must clearly state the time and place of preparation; information on the person preparing the record; information on the violating individual or organization; digital signature of the person preparing the record; the time and place where the violation was committed; administrative violation; rights and time limit for explanation regarding the administrative violation of the violator; and the agency receiving the explanation.

Tax agencies shall develop information technology systems that meet the requirements for preparing, sending, and electronically handling administrative violation records in accordance with the law on handling of administrative violations. When the information technology system meets the conditions for preparing and sending electronic administrative violation records regarding other violations of tax procedures and invoices, administrative violation handling shall be carried out electronically in accordance with the law on handling of administrative violations.”

22. To amend and supplement Clause 1, Article 37 as follows:

“1. Cases subject to explanation regarding administrative violations relating to tax and invoices:

a) Administrative violations relating to tax and invoices for which the maximum fine bracket for such violation is VND 15,000,000 or more for individuals, VND 30,000,000 or more for organizations, or cases involving preparation of electronic administrative violation records;

b) Administrative violations prescribed in Articles 16, 17, and 18 of this Decree.”.

23. To amend and supplement Point a, Clause 2, Article 41 as follows:

“a) Electronic civil status database or a court decision declaring a person as deceased or missing (the original or a copy of the paper document or of the electronic document as prescribed) in case where the individual is deceased or missing;”.

Article 2. Replacing a number of phrases; annulling a number of articles, points and clauses of articles and Appendices of the Government’s Decree No. 125/2020/ND-CP dated October 19, 2020, on sanctioning of administrative violations related to taxes and invoices

1. To replace the phrase “tax inspection” with the phrase “inspection” in the title of Article 15; Points d and dd, Clause 1, Point a, Clause 2, Article 15; Point b, Clause 2, Article 29; and Point a, Clause 2, Article 36 of Decree No. 125/2020/ND-CP.

2. To annul Clause 2, Article 7; Point b, Clause 1, Article 16; Articles 20 and 21; Clause 1 and Point a, Clause 3, Article 22; Article 23; Point a, Clause 1, Point a, Clause 4, and Clause 5, Article 24; Clause 2, Article 28; Clause 2, Article 32; Point d, Clause 2, Article 33; Article 34; and Clause 2, Article 35 of Decree No. 125/2020/ND-CP.

3. To annul all records and decision forms except for record Form 01A/BB in the Appendix on forms used for tax- and invoice-related administrative sanctions promulgated together with Decree No. 125/2020/ND-CP. Records and decision forms used for administrative sanctions in the field of tax and invoices shall comply with the Decree detailing a number of articles and measures for implementation of the Law on Handling of Administrative Violations. In administrative violation records and administrative sanctioning decisions in the field of tax and invoices, the competent sanctioning person shall additionally include information on the taxpayer’s tax identification number and fully reflect all contents of the applied remedial measures.

Article 3. Transitional provisions

1. For administrative violations related to tax and invoices that were completed before the effective date of this Decree, the provisions of the legal documents on sanctioning of tax- and invoice-related administrative violations in force at the time the violations were committed shall apply.

2. For administrative violations related to tax and invoices that were being committed before the effective date of this Decree and are detected after the effective date of this Decree, the provisions of this Decree shall apply.

3. For administrative violations related to tax and invoices that were sanctioned before the effective date of this Decree but for which individuals or organizations are still lodging complaints or initiating lawsuits, such cases shall be settled in accordance with the law on sanctioning of tax and invoice-related administrative violations and other relevant laws in force at the time the violations were committed.

Article 4. Effect and implementation responsibility

1. This Decree takes effect from January 16, 2026.

2. Ministers, heads of ministerial-level agencies, heads of government-attached agencies, chairpersons of People’s Committees of provinces and centrally run cities, and related organizations and individuals shall implement this Decree.