Which tax filings are mandatory for a newly established FDI company in Vietnam?

The first year of an FDI company is busy with capital contribution, hiring, office leases and trial production. Tax compliance easily drops to the bottom of the list, until the company receives its first penalty notice for a late return. From 1 July 2026, the Law on Tax Administration No. 108/2025/QH15 and Decree 252/2026/ND-CP replaced the previous framework, so checklists written under Decree 126/2020/ND-CP need updating. Below is the list of mandatory items we recommend every newly established FDI company review.

Right after receiving the Enterprise Registration Certificate

• Tax code: the enterprise code is also the tax code. Check the tax registration details, the managing tax office and the e-tax account.
• E-invoices: register for e-invoices before issuing the first invoice, under Decree 254/2026/ND-CP and Circular 91/2026/TT-BTC (which replaced Decree 123/2020/ND-CP, Decree 70/2025/ND-CP and Circular 32/2025/TT-BTC from 1 July 2026).
• VAT filing period: under Article 19.1 of Circular 89/2026/TT-BTC, taxpayers that have just started business may choose quarterly VAT filing. From the following year, companies with total revenue of VND 50 billion or less in the preceding year may continue to file quarterly.
• Business license fee: collection ended on 1 January 2026 under Article 10 of Resolution 198/2025/QH15, so companies set up from 2026 no longer declare or pay it.
• Direct investment capital account (DICA): capital contributions and later profit remittances must go through this account under SBV Circular 06/2019/TT-NHNN. Contributing capital through the wrong account is hard to fix later.
• Accounting regime: for financial years starting on or after 1 January 2026, Circular 99/2025/TT-BTC applies (replacing Circular 200/2014/TT-BTC). The company should adopt internal accounting rules accordingly.

Monthly, quarterly and per-transaction obligations

For provisional CIT, Article 24.3 of Decree 252/2026/ND-CP requires that total provisional payments for the 4 quarters are not less than 80% of the CIT due on the annual finalization; any shortfall attracts late payment interest from the day after the Q4 provisional deadline. Most FDI companies make losses in year one and pay nothing, but trading and service companies that are profitable from the start should watch this rule.

Annual obligations

1. CIT finalization: no later than the last day of the 3rd month after the financial year end (Article 10.5(a), Decree 252/2026/ND-CP). For a 2026 calendar financial year, the deadline is 31 March 2027. Tax losses can be carried forward for up to 5 consecutive years.
2. Related-party disclosure: FDI companies almost always transact with their parent or group companies (capital, loans, service fees, purchases and sales). Appendix I under Decree 255/2026/ND-CP must be filed with the CIT finalization return; the transfer pricing documentation (unless exempt) must be prepared before the finalization is filed.
3. PIT finalization: employers finalize by the same deadline as the annual CIT return (last day of the 3rd month). Individuals, including expatriates, who finalize directly have until the last day of the 4th month after the calendar year end.
4. Audited financial statements: the annual financial statements of foreign-invested enterprises must be audited under Article 37 of the Law on Independent Audit No. 67/2011/QH12. Under Article 25 of Circular 99/2025/TT-BTC, annual financial statements must be submitted to the competent authorities within 90 days of the financial year end.
5. Investment reporting: companies with investment projects file periodic reports on the National Investment Information System under the investment law (Law on Investment No. 143/2025/QH15, effective 1 March 2026, and its guiding documents).

Common first-year mistakes

• Pre-revenue costs are not collected and tracked properly, leading to disputes over deductibility at finalization.
• Service fees or royalties paid to the parent company without declaring foreign contractor tax within 10 days.
• Expatriates start working in Vietnam before a local labor contract is signed, and their income is not declared for PIT.
• No auditor is appointed before the financial year closes, causing the 90-day financial statement deadline to be missed.
• Input invoices of VND 5 million or more paid in cash, losing the VAT credit and the CIT deduction.

Illustrative example: A Japanese-owned limited liability company receives its Enterprise Registration Certificate in August 2026 and chooses quarterly VAT filing. The Q3/2026 VAT return is due on the last day of October 2026; if that day is a non-working day, the deadline moves to the next working day. The Q3 PIT return has the same deadline if salaries have been paid. The 2026 CIT finalization and audited financial statements are filed in March 2027.

How Kaizen can help

Kaizen supports Japanese, Korean and Singaporean invested companies from day one, from e-invoice registration and the filing calendar to finalization and audit preparation. Sign up for our free tax health check and we will build a compliance calendar for your company and review the risks we most often see in the first year.