越南税务登记：针对外国分支机构和代表处的新规

Vietnam’s tax authorities have issued (“OD 4937”), clarifying tax registration procedures for branches and representative offices of foreign companies operating in the country. The guidance implements the requirements under Decree No. 252/2026/ND-CP and Circular No. 90/2026/TT-BTC, introducing standardised registration procedures while expanding disclosure obligations relating to legal and beneficial ownership. For foreign companies, the changes extend beyond administrative compliance. The new requirements reinforce the tax authority’s risk-based approach to taxpayer management by improving transparency over ownership structures and strengthening the quality of taxpayer information available for ongoing supervision. Under the guidance, branches and representative offices that register directly with the tax authority must comply with updated procedures covering the entire tax registration lifecycle, including: Most registration and amendment applications must be submitted within 10 working days of the relevant event, while temporary suspension notices must generally be filed no later than one working day before the suspension takes effect. Electronic submission through the National Public Service Portal, the National Digital Identity Application, or the tax administration system is the default filing method. One of the most significant changes is the introduction of mandatory reporting on the legal owner and beneficial owner of the overseas parent company. During initial tax registration, branches and representative offices must submit Form BK07-DKT identifying both categories of ownership. Existing branches and representative offices that obtained tax codes before July 1, 2026, are required to submit the same information when making their next tax registration amendment. The guidance also requires taxpayers to: These requirements align tax administration more closely with Vietnam’s broader efforts to enhance transparency and anti-money laundering oversight. See also: Vietnam’s Mandatory Beneficial Ownership Disclosure Rules for Enterprises The guidance also outlines how provincial tax authorities will monitor compliance. Tax authorities are instructed to verify ownership information against government databases and other lawful information sources, standardise taxpayer data within the centralised tax management system, and proactively contact existing foreign branches and representative offices to obtain missing ownership information. Beginning in July 2026, the Tax Department will also conduct monthly monitoring of BK07-DKT submissions nationwide. The measures indicate that tax registration information is becoming an active compliance management tool rather than a one-time administrative filing. Foreign companies operating through branches or representative offices in Vietnam should review their tax registration records to ensure compliance with the new requirements. Particular attention should be given to the new beneficial ownership disclosure requirement (Form BK07-DKT), especially for entities that obtained their tax codes before 1 July 2026. Although the form is not required to be submitted immediately, it must accompany the entity’s next tax registration amendment. Businesses should therefore proactively identify and compile the required legal and beneficial ownership details to facilitate future tax registration updates and minimise potential administrative delays. Businesses with complex multinational ownership structures should also coordinate with their overseas headquarters to obtain accurate ownership information promptly before submitting any tax registration or amendment applications. As Vietnam continues to strengthen its risk-based tax administration framework and enhance ownership transparency, maintaining complete, accurate and up-to-date tax registration records will become an increasingly important aspect of corporate tax compliance. Key takeaways Foreign branches and representative offices must comply with updated tax registration procedures under Decree 252 and Circular 90. Failure to comply with the updated tax registration and reporting requirements may result in administrative penalties under Vietnam’s tax administration regulations. New disclosure requirements require reporting and updating information on both legal owners and beneficial owners of overseas parent companies. Establish internal procedures to ensure any changes to tax registration information are reported within the prescribed 10 working day deadline.