Jan 16, 2026
310/2025/ND-CP
Administrative Penalties for Tax and Invoice Violations in Vietnam
Decree 310/2025/ND-CP, effective January 16, 2026, replaces Decree 125/2020/ND-CP and introduces significant changes to administrative penalties for tax and invoice violations in Vietnam. The scope of violations has expanded to include land use fees, land and water surface rental fees, fees for granting mineral and water resource exploitation rights, after-tax profits of state-owned enterprises, and dividends from state capital in joint-stock and limited liability companies.
For the first time, the decree recognizes force majeure exemptions (natural disasters, epidemics, fires, wars) from penalties if taxpayers demonstrate they took all preventive measures. Crucially, penalty liability now extends to third parties: authorized agents and organizations/individuals performing tax obligations on behalf of taxpayers will be held directly responsible for violations. This has major implications for businesses outsourcing tax compliance and accounting services.
Invoice-related penalties are now structured in detailed tiers based on the number of invoices and their purpose (sales versus promotions/gifts/internal use). Fines range from VND 500,000 to VND 80 million depending on violation severity. Businesses must review their invoicing processes, especially for e-invoices, and ensure authorized representatives maintain full compliance to avoid serious legal and financial risks under this strengthened enforcement framework.
CRITICAL
VAT
Corporate Income Tax
E-Invoice