I. Legal basis

• Circular No. 89/2026/TT-BTC
• Circular No. 94/2026/TT-BTC
• 2025 Law on Tax Administration

II. Tax Department introduces key new provisions under Circular No. 89/2026/TT-BTC

1. On the classification of taxpayers for tax administration purposes

A new Article 4 is added to provide for the classification of taxpayers for tax administration purposes, comprising three clauses:

• Clause 1 provides for the purposes of classifying taxpayers for tax administration purposes, including determining preferential treatment in accordance with Article 48 of Decree No. 252/2026/ND-CP, allocating resources and applying appropriate management measures, conducting analysis and assessment of tax risks and the level of compliance with tax laws, and carrying out tax inspections and examinations based on the level of tax risk.
• Clause 2 specifically provides for the system of criteria for classifying taxpayers based on their area of operation, type of taxpayer, scale, business lines and sectors, legal form, ownership structure, level of compliance, compliance history, and level of tax risk.
• Clause 3 provides for appropriate measures based on the classification of taxpayers according to their level of compliance and level of risk, in order to apply corresponding management measures and ensure consistency and conformity with Circular No. 94/2026/TT-BTC dated 1 July 2026 of the Ministry of Finance providing guidance on risk management, compliance management, and risk management in tax administration.

2. On registration, modification, supplementation of information, and suspension of electronic tax transactions (Article 13)

• Additional provisions are introduced on the use of electronic identification accounts in accordance with the laws on electronic identification and authentication to conduct electronic tax transactions through the National Public Service Portal. Accordingly, taxpayers eligible to be issued electronic identification accounts shall use a Level 2 electronic identification account (for Vietnamese citizens) or an electronic identification account (for foreigners) to transact with tax authorities and update or modify their information on the National Public Service Portal in accordance with the guidance of the entity responsible for the information system (Clause 1).
• The provision on the time limit for taxpayers to update changes to or supplement information relating to their registration for electronic tax transactions with tax authorities is amended from “upon any change” to “within 03 working days from the date on which the change arises” (Point b, Clause 3).
• The provisions are amended and supplemented to clearly specify the cases in which taxpayers shall cease conducting electronic tax transactions, including cases where a taxpayer has been notified by the tax authority that it is not operating at the registered address and subsequently submits an application to carry out procedures for termination of the validity of its tax identification number or restoration of its tax identification number in accordance with the laws on tax registration.
• Additional provisions are introduced regarding taxpayers that have registered to conduct electronic transactions with tax authorities through the Portal of the Information System for Handling Administrative Procedures of competent state authorities, in order to ensure consistency with actual practice, as taxpayers currently do not carry out such procedures.
• In addition, certain procedures have been reviewed and simplified to ensure consistency with the provisions of the Law on Tax Administration and the laws on electronic transactions, including the removal of provisions on registration for electronic tax payment and the removal of provisions prescribing the time limit for notifying taxpayers of the acceptance or rejection of updated or supplemented information.

III. About Us, Hankuk Law Firm

■ Hankuk Law Firm – Introduction

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