Vietnam’s tax and customs landscape is undergoing a significant transformation as a series of new laws and regulatory changes are set to take effect in early 2025. These sweeping reforms, aimed at streamlining administrative processes, reducing burdens on businesses, and tightening oversight, come in response to longstanding concerns from the business community and policymakers alike. With the passage of key amendments and the introduction of new decrees, companies across multiple sectors—especially agriculture, trade, and import-export—are preparing for a new era of compliance and opportunity.
One of the most impactful developments is Decree 310/2025/ND-CP, which amends Decree 125/2020/ND-CP on administrative sanctions relating to tax and invoices. According to LuatVietnam, the new decree will officially take effect on January 16, 2025, and introduces a host of notable changes. For starters, the scope of violators has been expanded: now, not only traditional tax offenders but also those involved in other state budget revenue streams managed by tax authorities, as well as state capital investment at enterprises, are subject to the updated rules.
Crucially, the decree adds a comprehensive list of force majeure circumstances—think natural disasters, epidemics, wars, strikes, riots, and other unforeseeable events—that can exempt taxpayers from penalties if they have taken all necessary and possible measures to comply. This comes as a relief to businesses that have previously struggled with penalties during periods of disruption beyond their control.
Another major adjustment involves the way invoice violations are penalized. The new rules clarify that if a business commits the same invoice violation multiple times—such as issuing invoices at the wrong time—these will be treated as a single violation, with fines calculated based on the total number of erroneous invoices. The penalty system itself is now tiered, with fines ranging from 500,000 to 80 million VND depending on the number and nature of invoices involved. For instance, issuing promotional or complimentary invoices at the wrong time now carries a warning for the first offense, while more serious or repeated violations face escalating fines. The decree also introduces warnings for late or missing invoices in specific cases, a more lenient approach than the previous regime.
Beyond the technicalities, these measures aim to create a more predictable and fair environment for businesses, while enabling tax authorities to focus their energies on more egregious or systemic abuses. The full text of the decree is available for download as a unified electronic version, with a modest fee for access, as detailed by LuatVietnam.
Meanwhile, the customs sector is also seeing significant regulatory updates. On December 6, 2025, new policies were unveiled concerning goods entering and exiting bonded warehouses. According to the Finance and Customs Magazine, three previous conditions for recognizing bonded warehouses and designated collection points for export goods have been abolished, simplifying the process for businesses that rely on these facilities. This change is particularly relevant for companies that export goods to bonded warehouses and then re-import them—a common practice in global supply chains.
Customs procedures for transit vehicles—those temporarily imported for re-export or temporarily exported for re-import—have also been amended. The updates are codified in Clause 1, Article 49 of Decree 08/2015/ND-CP, as supplemented by Clause 27, Article 1 of Decree 167/2025/ND-CP, dated June 30, 2025. These adjustments are intended to reduce bottlenecks and confusion at the border, making it easier for companies to move goods in and out of Vietnam without unnecessary delays or paperwork.
Further clarifications are provided in Articles 85 and 88 of Decree 08/2015/ND-CP, as well as Article 91 of Circular 38/2015/TT-BTC, which was amended by Circular 39/2018/TT-BTC. These legal documents collectively ensure that businesses have a clear roadmap for compliance. The Customs Department has advised companies like Tokokosen Co., Ltd. to consult these regulations and reach out to their local customs units should any issues arise—an invitation that underscores the government’s willingness to provide guidance amid regulatory change.
Of course, no discussion of Vietnam’s evolving regulatory environment would be complete without addressing the ongoing debate over value added tax (VAT) policy, especially as it affects the agricultural sector. On November 26, 2024, the National Assembly passed Value Added Tax Law No. 48, which is set to take effect on July 1, 2025. Almost immediately, however, the government and Ministry of Finance began receiving feedback from business associations and enterprises about challenges in the application of VAT, particularly in agriculture, forestry, fisheries, and animal husbandry.
Responding to these concerns, the Ministry of Finance has proposed a series of amendments to the VAT law. The draft law, as presented by Minister of Finance Nguyen Van Thang, contains three main changes. First, it reintroduces a provision from 2014 allowing businesses, cooperatives, and unions involved in the production of agricultural, forestry, and fishery products to deduct input VAT without having to prepay it. This is a crucial step for sectors like coffee, food, and spices, where companies have had to front large sums—5,000 billion VND annually for coffee businesses alone—to cover VAT before applying for refunds. As Minister Thang explained, “This regulation has been implemented stably for many years, ensuring it does not violate the principles of value added tax, while also reducing the administrative burden for businesses and supporting production activities.”
The second proposed change is to remove a clause that previously imposed different VAT rates on products used for animal feed, ensuring that domestic producers are treated equally with importers. This move is intended to level the playing field and promote fairness in the animal feed market.
Third, and perhaps most controversially, is the recommendation to abolish the requirement that VAT refunds only be granted if the seller has already declared and paid the tax. According to Minister Thang, this rule was initially introduced as a stopgap measure to combat VAT fraud, but the draft Tax Administration Law now contains more robust provisions for managing tax compliance and refunds. As a result, the Ministry believes that maintaining this condition in the VAT law is unnecessary and potentially burdensome.
These changes are scheduled for review and possible adoption during the 10th session of the 15th National Assembly, reflecting the government’s ongoing commitment to dialogue and adaptation in the face of evolving economic realities.
Collectively, these reforms signal a new chapter for Vietnam’s tax and customs framework—one that balances rigor with flexibility, and enforcement with support for legitimate business activity. With the legal landscape in flux, companies would do well to stay informed, seek expert guidance, and prepare for both the challenges and opportunities that 2025 is sure to bring.
