Decree 291/2026/ND-CP on administrative tax and invoice penalties

31 July, 2026

On 21 July 2026, the Government issued Decree 291/2026, amending Decree 125/2020 on administrative penalties relating to tax and invoices. Decree 291 took effect immediately upon issuance.

Decree 291 introduces new penalties for failing to provide information requested by the Vietnamese tax authorities for tax information exchange purposes. Country-by-Country Report (“CbCR”) is one of the tax documentation requirements that falls within the scope of tax information exchange. Accordingly, non-compliance with the relevant filing and notification obligations under the three-tiered transfer pricing documentation framework may be subject to the new penalty regime introduced under Decree 291.

Required fields are marked with an asterisk(*)

By submitting your personal data to us, you acknowledge that you have read the Privacy Statement and that you consent to our processing in accordance with the Privacy Statement. If you change your mind at any time,you can send us an email message using the Contact Us page.

Get in touch

Dinh Thi Quynh Van

Chairwoman, PwC Vietnam

Tel: +84 24 3946 2246

Judith Henry

Partner, Transfer Pricing Services, PwC Vietnam

Tel: +84 28 3823 0796, Ext. 1525

Nguyen Le Nhan Hoa

Director, Transfer Pricing Services, PwC Vietnam

Tel: +84 28 3823 0796

Ngo Thanh Tin

Director, Transfer Pricing Services, PwC Vietnam

Tel: +84 28 3823 0796

Hide