Official Letter No. 1927/CT-KT dated March 31, 2026, issued by the Tax Department on strengthening tax administration for enterprises with prolonged losses and low profit margins

Accordingly, the Tax Department has reviewed and compiled a list of certain enterprises with revenue from the sale of goods and services of VND 1,000 billion or more that incurred losses for two consecutive years, 2023 and 2024 (details are provided in Appendix II attached).

List of 302 enterprises: here.

The Tax Departments of provinces/cities, the Large Enterprise Tax Sub-Departments, and the E-commerce Tax Sub-Departments are requested to review the above-mentioned list and update data on business performance results based on the 2025 Corporate Income Tax (CIT) finalization declarations of the enterprises under their direct management, in order to analyze and identify enterprises with high tax risks and include them in the inspection plan under the 2026 thematic program.

The list of enterprises proposed for inclusion in the thematic inspection plan shall be reported by the respective units to the Tax Department (via the Inspection Division) within April 2026.

*Notes on conducting tax inspections for enterprises with prolonged losses and low profit margins:

When carrying out inspections of enterprises with prolonged losses and low profit margins, attention should be paid to the following:

• Review the reasonableness of revenue, expenses, and profits, particularly large or unusual expenses. Compare and reconcile the fluctuation rates of revenue with those of corresponding input costs; review and cross-check with relevant supporting documents and records.
• Examine the timing and basis for revenue recognition and output VAT to ensure compliance with the correct accounting and declaration periods; cross-check relevant documentation to verify proper revenue recognition and accurate determination of tax liabilities, avoiding underreporting or fictitious declarations.
• Review VAT input and output declarations; inspect invoices and supporting documents to ensure their validity and proper declaration periods.
• Inspect and review documentation related to cost of goods sold, administrative expenses, selling expenses, etc., incurred during the period to ensure that such expenses serve the enterprise’s production and business activities.

During the inspection process, particular attention should be given to intra-group interest expenses and intra-group service fees, such as shared service center charges, technical service fees, management support fees, royalties, franchise fees, etc., ensuring that they are consistent with the arm’s length principle and contribute to generating revenue and income for the taxpayer’s business activities. Additionally, contracts for the purchase and sale of goods with related parties should be thoroughly reviewed to ensure compliance with the arm’s length principle in determining purchase and selling prices.

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