Colluding with or shielding a taxpayer may result in fines of up to VND 100 million

On July 21, 2026, the Government issued Decree No. 291/2026/ND-CP, amending and supplementing a number of articles of Decree No. 125/2020/ND-CP on penalties for administrative violations in the fields of tax and invoices.

Under Article 2 of Decree No. 291/2026/ND-CP, which adds Article 19a, Point b, Clause 3, Article 19a imposes a fine ranging from VND 50 million to VND 100 million for the following violation:

Colluding with or shielding a taxpayer to obstruct a tax office from collecting or verifying information for information exchange purposes under Vietnamese law or a treaty or international agreement on taxation to which the Socialist Republic of Vietnam is a member or signatory.

Accordingly, not every act of colluding with or shielding a taxpayer is subject to this penalty. The sanction applies only where such conduct is intended to obstruct a tax office from collecting or verifying information for tax information exchange purposes under Vietnamese law or under international tax treaties or agreements to which Vietnam is a member or signatory.

In addition, Clause 3, Article 19a also imposes a fine ranging from VND 50 million to VND 100 million for failing to provide information within 15 days after the expiration of the time limit for providing information or the extended time limit for providing information as requested by a tax office for information exchange purposes under Vietnamese law or a treaty or international agreement on taxation to which the Socialist Republic of Vietnam is a member or signatory.

Furthermore, the fines prescribed in Article 19a apply to organizations. For the same violations committed by individuals, the fine is equal to one-half of that imposed on organizations. Households and household businesses are subject to the same fines as individuals.

Decree No. 291/2026/ND-CP takes effect on July 21, 2026.

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