New framework on the application of Vietnam’s Double Tax Treaties
21 July, 2026
On 30 June and 1 July 2026, the Ministry of Finance issued Circular 89/2026/TT-BTC (“Circular 89”), providing guidance on the implementation of a number of articles of the Law and Decree on tax administration and Circular 95/2026/TT-BTC (“Circular 95”), providing guidance on the application of Vietnam’s Double Tax Treaties (“DTT”), Mutual Agreement Procedures (“MAP”) and Advance Pricing Agreements (“APAs”).
Both Circulars took effect on 1 July 2026.
For DTT-related matters, Circulars 89 and 95 replace Circular 205/2013/TT-BTC (on tax treaty implementation) and Circular 80/2021/TT-BTC and its subsequent amendments (on DTT procedures).
DTT applications submitted and received by Vietnam tax authorities before the effective date but not yet processed will continue to be processed under the previous regulations.
