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When every transaction leaves a trace.

money tracing
Category
Context

The National Assembly’s message

On August 08th, 08, at the ceremony commemorating the 2026th anniversary of the Economic Police Force's traditional day, National Assembly President Tran Thanh Man delivered a speech, urging the force to take the lead in applying science and technology, leveraging data, strengthening digital investigation capabilities and tracing financial flows. He also emphasized the need to proactively identifying new emerging risks to economic security, financial security, data security, and supply chain.

It is clear that "tracing financial flows" has now become an officially recognized objective at the highest level of leadership. This message is reflected in a series of regulatory measures introduced over the past 18 months, including: electronic invoices generated from cash registers, non-cash payment thresholds, the abolition of lump-sum tax regime, beneficial ownership disclosure requirements, and most recently, the obligation to provide bank account data to the tax authorities.

Taken together, these new regulations all serve a consistent strategic direction: Digitizing tax administration, continuously monitoring financial-flow data, conducting risk-based reviews, and building a comprehensive digital financial ecosystem.

money tracing
Electronic invoices, bank account data, and beneficiary identification are now being connected into a unified financial-flow monitoring infrastructure.
The big picture

Convergence of data streams

 To trace financial flows across the economy, regulators need to be able to answer three questions for every transaction: Who sold? — Where did the money go? — Who ultimately benefited? Over the past three years, the Vietnamese government has progressively developed three corresponding layers of data, designed to be cross-referenced against one another.

Transaction data — electronic invoices

Most businesses, organizations, household businesses and individual business owners are subjected to electronic invoicing requirements now use electronic invoices and connected cash registers that record each sale and transmit the relevant data directly to the tax authorities .

Financial-flow data — banking

From July 01st, 07, banks and payment intermediaries are required to periodically provide tax authorities with information on transaction information, account balances, beneficial ownership information, and suspicious transaction data.

Identification data — Tax Identification Numbers & Beneficial Ownership

Tax identification numbers are linked to individual identification data; businesses are required to declare their beneficial owners; e-commerce platforms with payment functionality withhold tax at source, linking revenue to the ultimate beneficiary.

28+ billion

Electronic invoices have been received and processed by the tax authorities (cumulative up to July 2026).

≈ 250 million

Bank accounts are in the tax authority's database, of which approximately 200 million are individual accounts.

5 million VND

The threshold which non-cash payment documentation is required to be eligible for input VAT deduction.

Source: Tax Department — Ministry of Finance.

When these three data streams are cross-referenced, the "blind spots" in accounting records quickly disappear: A deposit into a bank account without a corresponding invoice, or a high-value invoice without a corresponding cash flow – all these suspicious transactions become signals that attract the attention of the system.

Regulatory roadmap

Every piece is falling into place

Looking at the overall picture, the implementation timeline shows a carefully coordinated progression:

01/06/2025

E-invoices generated from cash registers

Households and individuals engaged in retail, food and beverage, and service businesses (with annual revenue exceeding 1 billion VND) are required to use connected cash registers that transmit sales data directly to the tax authorities.

Decree 70/2025/ND-CP amends Decree 123/2020/ND-CP

01/07/2025

Three regulations take effect on the same day.

  • The non-cash payment threshold was reduced from 20 million VND down to 5 million VND: Purchases supported by invoices of 5 million VND or more must be accompanied by evidence of non-cash payment to be eligible for VAT deduction. - Value Added Tax Law 48/2024/QH15, Decree 181/2025/ND-CP
  • E-commerce platforms responsible for tax payment: Platforms with payment functionality are required to withhold, declare, and pay VAT and personal income tax on a transaction-by-transaction basis for household and individual business owners. - Decree 117/2025/ND-CP
  • Beneficial ownership disclosure: Companies are required to disclose the individuals who ultimately own or control the business. - Law No. 76/2025/QH15, Decree 168/2025/ND-CP
10/12/2025

The National Assembly passed the new Tax Administration Law.

The law formalizes data-driven and risk-based tax administration; introduces two new chapters on international cooperation and risk management/digital transformation; and shortens the deadline for filing supplementary tax returns from 10 years to 5 years.

Law on Tax Administration No. 108/2025/QH15

01/01/2026

Abolition of the Lump-sum Tax regime

Household and individual businesses move to a self-declaration and self-payment model based on actual revenue data. This ends the fixed tax mechanism that had been in place for decades, bringing millions of household businesses onto the same data framework as enterprises.

Resolution 198/2025/QH15

01/07/2026

Banking data connected to the tax authorities.

The 2025 Law on Tax Administration and Decree 252/2026/ND-CP take effect: banks and payment intermediaries are required to provide account data; tax refunds, exemptions, and reductions are automatically processed based on risk criteria; and prioritizes remote tax inspections using electronic data.

Decree 252/2026/ND-CP replaces Decree 126/2020/ND-CP.

08/08/2026

"Financial-flow tracing" message

The National Assembly Chairman called on the Economic Police force to take the lead in digital investigations and tracing financial-flows — effectively closing the loop between tax data, banking data, and investigative capabilities.

2026 → 2030

Moving towards international standards and big-data centers

The National Action Plan on Anti-Money Laundering for the period of 2026–2030 (Decision 707/QD-TTg); preparation for the APG multilateral assessment in 2028; and by 2030, a direction towards developing big-data centers, integrating invoices, declarations, financial reports and cross-sectoral data.

Spotlight: 01/07/2026

What can the tax authorities see?

Amongst all of these developments, the most impactful change for business owners is Decree 252/2026/ND-CP. Previously, under Decree 126/2020/ND-CP, banks were required to periodically provide account identification information; transaction data and account balances were provided only when requested by the tax authorities for inspection, audit, or enforcement purposes.

Content Before July 01st, 07 · Decree 2026/126 Effective from July 01st, 07 · Decree 2026/252
Transactions and account balances Provided only upon request by tax authorities (for inspections, audits, or enforcement actions). Subject to provision
Suspicious transaction Reviewed upon request by tax authorities. Proactively reviewed and provided in accordance with anti-money laundering laws.
Beneficial ownership Not yet regulated Subject to provision
Data standard Not yet regulated According to the standards of the Global Forum on Transparency and Exchange of Tax Information.

Compiled from Decree 126/2020/ND-CP and Decree 252/2026/ND-CP

From July 1st, 2026, the following four categories of information are subject to mandatory provision:

Identification, transactions, and account balances

Account numbers linked to tax identification numbers; transaction volumes, values, details of the transaction; information on the sender and recipient; domestic and cross-border transactions; account balances, period-end balances, and income generated through the account.

Unusual and suspicious transactions

Banks are required to proactively review and provide information in accordance with anti-money laundering laws, while also cooperating when unusual transactions are identified that may require tax compliance inspection — rather than reviewing only when specifically requested.

Beneficial owners and related parties

Authorized persons, co-account holders, beneficiaries, and other parties associated with the account — creating a direct link with the obligation to disclose beneficial owners to the business registration authority.

Accounts of non-residents

Financial account information relating to persons who are not tax residents of Vietnam, in accordance with the standards of the Global Forum on Transparency and Exchange of Information for Tax Purposes — paving the way for cross-border data exchange.

The objective of these new regulation is to integrate electronic invoice data with financial-flow to create a taxpayer data "ecosystem", shifting towards tax administration based on financial-flow analysis. This new framework is also accompanied by stronger enforcement measures — for example, a temporary suspension of departure from Vietnam is imposed on individuals with overdue tax debts exceeding 120 days of 50 million VND (for household and individual business owners) or 500 million VND (for legal representatives of enterprises).

💡 Correct understanding

Tax officials don't manually scrutinize every bank account. The data is processed and cross-referenced automatically by the system based on risk criteria. The risk becomes significant only when different data sources relating to your business contradict one another.

Data infrastructure

Tax inspections begin before the inspectors arrive

What distinguishes this new phase is not simply the collection of data — but the ability to process that volume of data. In the first seven months of 2026 alone, the system received approximately 7 billion additional electronic invoices. Based on this data, the tax authorities are operating three major analytical tools:

K
K-factor Alerts

The system compares the value of output invoices with the business' input capacity and actual operating characteristics. Businesses that issue invoices beyond their apparent operating capacity will be flagged by the system as early warning, and may even be blocked from issuing invoices.

⛓
Transaction-chain Analysis

Rather than examining each taxpayer file in isolation, the system traces multi-layer chains of purchases-and-sales to identify fraudulent invoices and "shell" businesses with no warehouses, employees or assets but reporting substantial sales.

⛬
Three-way Data Reconciliation

Invoices ↔ bank statements ↔ tax returns. Discrepancies between these three data sources represent an initial risk indicator that can trigger an inspection on the taxpayer's files — even before any inspection team arrives.

135,000+

Taxpayers monitored and alerted by the system regarding electronic invoices usage (cumulative up to June 30th, 2026).

5,000 billion VND

The amount of VAT that approximately 31,000 taxpayers proactively adjusted in their tax declarations following the system alerts.

400+

Cases showing signs of serious violations that have been transferred to the investigative authorities.

Figures compiled by the Tax Department.

The 2025 Tax Administration Law also clarifies the principle of prioritizing remote inspections based on electronic data — meaning that most future inspections will take place within the system, rather than at the business' premises. The results of the transaction-chain analysis will not only be used for tax refund applications but may also serve as a basis for tax inspections and the transfer of cases to the police. Cross-sectoral coordination and data sharing between the tax authorities, customs, police, and banks are also being strengthened.

Management perspective

What does this mean for your business?

At first glance, these changes might seem overwhelming. But viewed from the right perspective, they represent a significant advantage for businesses that operate transparently and have standardized operating procedures.

Old habits become potential risks.

  • Off-book revenue, omitted invoices — creating immediate discrepancies with cash flow into the account.
  • Using personal bank account to receive or make payments for business transactions.
  • Paying in cash for invoices of 5 million VND or more — resulting in the loss of VAT deduction rights and other deductible expenses.
  • Purchasing invoices — leaving traces that can be exposed through transaction-chain analysis.
  • Allowing someone else to use your name or acting as a nominee owner — creating beneficial ownership disclosure obligations.

Transparent businesses have the advantage.

  • Lower risk rating: fewer tax inspections and audits; faster automated processing of tax refunds, exemptions and reductions.
  • Clean financial data facilitates easier access to loans, fundraising, and M&A due diligence.
  • The cost of getting things right from the outset is always less than subsequent back taxes, penalties, and late payment interest.
  • Greater eligibility to participate in the supply chains of FDI companies and partners with high compliance requirements.

"Proper understanding — Proper practices. Identifiying errors before the tax authorities do is the greatest advantage a business can have."

Expertis, your trusted partner
Prepare for the era of data-driven tax administration — Before the data "speaks" for you.
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ⓘ This article is compiled and analyzed based on legal documents and publicly available data at the time of updating. The content is for general informational purposes only and does not replace legal or tax advice for specific cases. Please contact Expertis experts for advice tailored to your business situation.
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