2026 TAX LAW BREAKTHROUGH: DELETE 22 CIRCULARS AND 03 DECISIONS ON TAX

The Ministry of Finance has recently promulgated Circular No. 110/2026/TT-BTC, officially repealing 22 Circulars and 03 Decisions in the field of taxation. This is regarded as a comprehensive overhaul of the tax regulatory framework, aimed at eliminating overlapping, expired, or outdated legal instruments that are no longer compatible with modern tax administration.

1. What is the nature of this large-scale repeal?

Upon hearing that “22 Circulars have been repealed,” many businesses may understandably become concerned: Does this create a legal vacuum? Will tax declaration procedures or tax incentives be abolished?

Expert Insight: This repeal does not abolish tax obligations or dismantle existing tax administration mechanisms. Rather, it is a legal “clean-up” exercise intended to streamline the legal framework. The 25 repealed legal instruments generally fall into three categories:

• Legal instruments whose implementation period has expired (e.g., Circulars providing tax exemptions or reductions applicable during previous economic crisis periods).
• Legal instruments that have been entirely superseded by the new Law on Tax Administration, the amended Law on Value-Added Tax (VAT), the amended Law on Corporate Income Tax (CIT), and the recently consolidated implementing Decrees.
• Administrative procedural regulations that are no longer compatible with digital tax administration, electronic invoicing, and centralized data management.

2. Key points requiring immediate attention

To avoid inadvertently relying on repealed legal instruments or citing incorrect legal bases in tax documentation, legal and accounting departments should promptly review the following:

A. Review the internal reference document system

• Issue: Many accounting manuals, internal control procedures, or consulting agreements continue to cite outdated Circulars as the legal basis for determining deductible expenses, eligibility for tax incentives, or tax filing procedures.
• Action: Immediately update the list of repealed legal instruments in accordance with Circular No. 110/2026/TT-BTC. Replace such references with the currently applicable Laws, consolidated Decrees, and the latest Circulars.

B. Review pending tax exemption, reduction, and refund files

• Procedures governing tax exemptions and reductions under the repealed legal instruments will henceforth be fully governed by the standardized procedures prescribed under the new Law on Tax Administration and the eTax electronic tax services system.
• Do not use the forms, templates, or hard-copy documentation previously prescribed under the repealed Decisions or Circulars.

3. Self-assessment compliance checklist for businesses

To ensure full compliance with the current legal framework, businesses should promptly undertake the following actions:

• Update accounting software and ERP systems: Ensure that the system no longer retains outdated legal references or codes relating to tax exemptions or reductions.
• Review legal references in tax explanations and submissions: When working with tax authorities during tax finalization or audit processes, do not cite Circulars included in the list of legal instruments repealed under Circular No. 110/2026/TT-BTC.
• Provide short-term training for accounting and finance personnel: Disseminate the list of the 25 repealed legal instruments to ensure that relevant personnel clearly understand the currently applicable legal framework.