6 RISK OBLIGATIONS TAX KEY FROM 01/07/2026

The advent of the Decree 252, 253 and 254 2026 (effective from 01/07/2026) marked a turning point in the digitization comprehensive and tightens the discipline of the tax. Below are legal analysis brief on 6 risk critical that businesses need to control immediately to avoid compensation and financial losses.

I. Group risk Management Tax (Decree 252/2026/ND-CP)

1. Risk assessment of duties and taxes due related data cross

The new decree allows The tax authorities for projectors automatically, in real-time (real-time) between the data flow of money from the Bank, Customs declaration and insurance agency. Any imbalance between realistic cash-flow and revenue declaration will immediately take business into the “black list”, for face-to-face with the decision of the tax assessment and penalties for tax evasion.

2. Dissection costs rigorous in the transaction link

The principle of “quality decide the form” (substance-over-form) is specified with the criteria extremely quantitative. The profile determine the transaction price the missing link records the fact, or the loan group internal’t prove to be essentially independent trade will be automatically excluded from the cost reasonable, drag in arrears CIT large volume.

II. Risk group personal income Tax – PIT (Decree 253/2026/ND-CP))

3. Trace worldwide income and benefits ‘soft’

Through the mechanism of exchange of information automatically (CRS), international risk arrears PIT for foreign experts, and the high level is very high. The benefits of non-traditional (stocks, rewards, token, options, pension insurance, international) is required to convert and declare accurate. The dissection in the wrong account “fringe benefits” will lead to the risk of administrative penalties and interest for late payment is progressive.

4. Deduction wrong nature with respect to the self-employed (Gig workers)

Every effort legalize costs by splitting the contract or switch the wrong nature from Contract labor to Contract services to evade coverage and pressure the deduction PIT false will be the AI system of the directorate General of Tax identification through the individual tax code. Businesses will be responsible for filing a change and the whole of the property.

III. Risk group Bill electronic vouchers (Decree 254/2026/ND-CP))

5. Supply chain ‘tainted’ the bill risks

System management bill new application of the “alert text”. If a vendor at the branch F2, F3 signs of risk (fled, sale, purchase, invoice), the entire cost of input VAT and the cost and CIT respectively of business (F0) will be the system freezes or the payment until there is accountability valid evidence from the actual receipt.

6. Violation time stamp (Timestamp) when the invoice

The difference between the moment of acceptance/transfer of real goods and time stamp digital number recorded on the system level code of The tax authority will be under strict control. The backward day, the invoice at the wrong time is put into group violations are high risk, applying the framework of administrative violations extremely heavy, according to the principle of accrual.

Recommended action: Businesses need to urgently implement Internal Audit (internal audit) comprehensive. Highest priority for setting up roadblocks to check the operational status of the supplier before payment and standardize the regulation of salary bonus (Total Rewards) to ensure compliance from day 01/07/2026.