Vietnam Finance Ministry proposes new tax risk monitoring rules

The Vietnamese Ministry of Finance is consulting on a draft circular that would introduce risk‑based management and compliance controls for taxpayers. Under the proposal, any taxpayer showing one of several warning signs – such as suspicious bank transactions linked to tax evasion, being prosecuted for tax‑related offenses, a high‑risk profile identified by tax authorities, or failure to respond to compliance requests – could be placed under intensive tax surveillance and have their case forwarded to police investigators.

The draft categorises taxpayers into three risk levels – high, medium and low – based on compliance ratings (good, average, poor, non‑compliant) and criteria like business scope, size and industry. High‑risk taxpayers may face tighter audit procedures, restrictions on electronic invoicing, increased debt‑recovery actions, travel bans and other enforcement measures. Medium‑ and low‑risk groups would receive proportionate oversight, ranging from support programs to routine checks.

An accompanying document outlines a four‑tier compliance classification (levels 1‑4) and sets out differentiated management actions: priority treatment for low‑risk, compliance‑support for medium‑risk, and warnings, monitoring, on‑site inspections and possible travel restrictions for high‑risk entities. The reforms aim to shift from uniform tax administration toward a data‑driven, risk‑focused approach.