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Doctors, lawyers, teachers, and real estate brokers are subject to review and retroactive collection of personal income tax.

Key points

📌 The sectors targeted for tax audits and reviews include:

In early August 2026, the Ho Chi Minh City Tax Department issued a plan for specialized inspections to strengthen the management of personal income tax for high-income earners, focusing on four areas: healthcare, education and training, sports, culture and tourism, and legal services and real estate brokerage. According to the tax authorities, these are professions where many individuals earn high incomes from multiple sources but have not fully fulfilled their tax obligations.

personal income tax review
Four high-income industry groups are subject to tax audit and review.

Who is subject to the 2026 personal income tax audit and review?

The key focus areas of the plan include:

Sectors Career
Health - Healthcare Doctors; pharmacists; nurses, midwives; medical technicians; clinical psychologists; clinical nutritionists…
Education and Training University lecturers; teachers from preschool to high school…
Sports – Culture – Tourism Sports coaches; tour guides; actors, professional performing artists…
Legal – Real Estate Brokerage Lawyers; notaries; bailiffs; arbitrators; auctioneers; appraisers; real estate brokers; real estate managers…

Quick self-check

01

Are you currently working in one of the four professions listed above?  Do you have a license or professional certificate issued by a relevant government agency?

The list of licenses and professional certificates is one of the data sources for the review.

02

In the last 5 years, have you had income from two or more sources? vFor example: salary at the main unit plus fees for teaching, consulting, after-hours medical examinations and treatment, brokerage commissions, performance fees, etc.

Having multiple sources of income is a common characteristic of the groups that tax authorities focus on auditing and reviewing.

03

Is there a year when you didn't file your own personal income tax return?  Or perhaps you don't remember which years you did it and which years you didn't?

When you have income from two or more sources, you must compile all sources and file your own tax return. This is the most common reason for underreporting taxes.

If you fall into category 1 and at least one of the other two categories, you are in the highest risk group for the 2026 personal income tax audit and should review your situation immediately.

Risks of underreporting personal income tax in 2026

According to the provisions of Clauses 7 and 8 of Article 44 Law on Tax Administration 2025 No. 108/2025/QH15:

05 year

Statute of limitations for imposing penalties for the following offense:

  • False declaration This leads to a tax shortfall or an increase in the amount of taxes exempted, reduced, refunded, or not collected;
  • Tax evasion It is not serious enough to warrant criminal prosecution.

10 year

Statute of limitations for recovering the money Tax arrears + late payment penalties From the date the violation was discovered onwards, even if no penalty was imposed, it was because the statute of limitations for imposing penalties had expired according to regulations.

Not registered for tax 

The full amount of outstanding taxes, evaded taxes, and late payment penalties for the entire period prior to the date the violation was discovered must be recovered.

Temporary suspension of departure

Individuals with outstanding tax debts will be prohibited from leaving the country.

⚠️ Tax audits and collection of personal income tax prior to 2026 will continue even if the statute of limitations for penalties has expired.

Many people think that old mistakes are "overdue after 5 years." However, the expiration of the statute of limitations for penalties only means... No more fines — the outstanding tax amount and late payment penalties must still be paid in full. as per regulations.

In addition, point c, clause 2, Article 8 Decree 253/2026/ND-CP regulations: in the case Individuals providing services without business registration.The remuneration from this activity is defined as income, salary, or wages. Some common examples include: doctors providing after-hours consultations, lawyers offering private advice, freelance real estate brokers, etc.

At that time, the tax was recalculated according to a progressive tax rate system with the highest tax rate reaching 35%; The difference will be reviewed, collected, along with late payment penalties and administrative fines for violations of personal income tax regulations in 2026.Given that data on money flows through banks, e-commerce platforms, and digital platforms are already connected to tax authorities, the potential for verification and detection is very high.

👉 See more: No business registration: Personal income tax will be collected retroactively at a rate of 35%, similar to salary and wage income, starting from July 1, 2026.

Recommended actions

01

Review all sources of income.

Log in eTax MobileGo to the section for tax settlement/income information lookup to search for the amounts that the payers have declared for their tax identification number.

02

Compare year by year — at least the last 5 years

Summarize income from all sources by year; compare with tax deduction certificate Received; determine which years have been settled, which have not, and the remaining tax difference to be paid (if any).

03

Submit supplementary information and all required documents before inspection.

According to Clause 2, Article 44 Law on Tax Administration 2025The taxpayer has submitted supplementary documents and voluntarily paid the full amount of tax. before the tax authorities announce the inspection decision. (or before the tax authorities find out) not penalized for making false declarations. — You only need to pay the outstanding tax amount and late payment penalties for the tax paid late.

04

Standardize tax obligations for the coming years.

Centralized tracking of incidental income; required. withholding tax certificate issued immediately upon receipt of remuneration.Identify the specific cases where self-assessment is necessary instead of delegation. If the revenue source is complex or the data from multiple years is unclear, it is advisable to have a tax expert involved from the initial review stage.

05

Proactively register your business.

If there are multiple sources of supplementary, occasional income that are business-oriented (regular, self-organized, and subject to risk), Consider registering as a household or individual business. to be eligible for an appropriate tax rate that reflects the true nature of the activity.

Expertis, your trusted partner
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Q&A

This thematic inspection plan is by Ho Chi Minh City Tax However, tax data is now interconnected nationwide, and tax identification numbers are linked to personal identification numbers, so your tax obligations will still be fully displayed on the system regardless of where you work. Individuals in other localities should proactively review their tax information as a precautionary measure, rather than waiting for a similar plan to be announced in their place of residence.

No. The statute of limitations for penalties has expired, you Although not subject to administrative penalties, they are still required to pay the full amount of outstanding taxes, evaded taxes, and late payment interest. in 10 years ago from the date the violation is discovered. In the case of individuals who have never registered for tax, the retroactive tax collection will apply to the entire period prior to the date the violation is discovered.

✅ Yes — for making false declarations. If you submit supplementary documents and pay all taxes. before the tax authorities announce their decision to conduct an audit.You will not be penalized for false declarations and will only have to pay late payment fees (Clause 2, Article 44 of the 2025 Tax Administration Law).

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