Author: Ms. Thai Thi Van Anh – Director of Ho Chi Minh City Branch, KTC Auditing Company Limited; Member of the ACCA Vietnam Tax and Law Committee
Executive Summary
Vietnam’s E-Commerce Law No. 122/2025/QH15 and Law on Tax Administration No. 108/2025/QH15 mark an important shift in the regulation and tax administration of business activities in the digital economy. As tax authorities increasingly collect and cross-check transaction data, businesses need to focus not only on tax declaration and payment obligations but also on maintaining consistency across revenue records, invoices, cash flows and accounting data. Drawing on the professional insights shared by Ms. Thai Thi Van Anh in an interview with the Tax and Customs publication of the Economics and Finance Magazine under Vietnam’s Ministry of Finance, this article examines key regulatory developments and practical considerations for businesses.
Recent changes in e-commerce tax administration have attracted considerable attention, particularly regarding the tax obligations of household businesses, individual business operators and online sellers. However, the implications of increasingly data-driven tax administration extend well beyond these groups.
For e-commerce platform operators and businesses selling through multiple channels, determining the appropriate tax obligations, reconciling revenue and maintaining consistency between transaction records, invoices and cash flows are becoming increasingly important aspects of tax compliance management.
1. E-Commerce Tax Administration: A Shift Towards Data-Driven Oversight
Vietnam’s E-Commerce Law No. 122/2025/QH15 and Law on Tax Administration No. 108/2025/QH15, both effective from 1 July 2026, provide a legal foundation for strengthening the administration of business activities in the digital environment.
One notable development is the expanding ability of tax authorities to collect and cross-check information from e-commerce platforms, payment transactions and other relevant parties. Rather than relying primarily on taxpayers’ self-declared information, tax authorities now have access to additional data sources to identify business activities and assess potential tax risks.
The increasing use of technology and data-driven tax administration also means that discrepancies between declared revenue, electronic invoices, platform transaction data and cash flows may become more readily identifiable.
For businesses, this reinforces the importance of proactively reviewing the accuracy, completeness and consistency of accounting and tax data, rather than addressing discrepancies only when explanations are requested by regulatory authorities.
Enhanced data reconciliation capabilities also have implications beyond transactions arising from 2026 onwards. Discrepancies in revenue recognition, invoicing and tax declarations relating to previous tax periods may also require explanation if the tax authorities conduct an examination or inspection in accordance with applicable regulations.
Accordingly, alongside monitoring new regulatory developments, businesses should also review the consistency of transaction data and tax records from previous periods, taking into account the legal requirements applicable at the time of each transaction.
2. Clearly Defining Tax Responsibilities Across the E-Commerce Ecosystem
E-commerce activities may involve multiple participants, including businesses selling goods or services, platform operators, payment service providers and other intermediaries.
Depending on their roles, operating models and applicable regulations, these participants may be subject to different obligations concerning taxation, information disclosure and cooperation with regulatory authorities.
Notably, under Decree No. 117/2025/ND-CP and Decree No. 68/2026/ND-CP, platform operators falling within the prescribed scope are responsible for withholding, declaring and remitting taxes on behalf of household businesses and individual business operators in respect of relevant transactions.
Importantly, this mechanism does not mean that platforms assume the tax obligations of all businesses selling through their systems. Corporate sellers remain responsible for determining and fulfilling their own tax obligations in accordance with applicable regulations.
For platform operators, meeting these statutory responsibilities also requires effective transaction management, appropriate treatment of transaction adjustments and accurate reconciliation of tax withholding and remittance data.
3. Four Key Areas Businesses Should Proactively Review
First, reconcile revenue across multiple sales channels.
Businesses selling through e-commerce marketplaces, their own websites, social media platforms and physical stores need to ensure that revenue is recorded completely, in the appropriate accounting periods and in accordance with the substance of the underlying transactions.
Discounts, sales returns, cancelled orders and promotional programmes should be appropriately classified and accounted for to minimise discrepancies between sales records, accounting data and tax declarations.
Second, distinguish sales revenue from the net amounts received from platforms.
In e-commerce operations, the amounts transferred by platforms to businesses are often net of service fees, payment processing charges, advertising expenses, shipping fees and other adjustments. Therefore, the net amount received does not necessarily represent the revenue that should be recognised for accounting or tax purposes.
Businesses should reconcile platform transaction reports against fees, discounts, refunds and relevant supporting documentation to determine the appropriate treatment of revenue, expenses, invoicing and tax declarations.
Particular attention should be paid to the nature of promotional programmes, vouchers and platform-funded incentives to avoid incorrect accounting treatment or insufficient supporting documentation for related expenses.
Third, determine tax obligations according to the business model.
Direct sales, marketplace-based transactions, digital service provision and arrangements involving overseas business partners may give rise to different tax obligations.
Businesses should examine the substance of transactions, contractual arrangements and the roles of the parties involved to determine the applicable Value Added Tax (VAT), Corporate Income Tax (CIT) and other relevant tax obligations, including Foreign Contractor Tax (FCT) where applicable.
Fourth, strengthen transaction data management and record retention to support tax explanations.
As tax authorities gain greater capabilities to cross-check information from multiple sources, maintaining complete transaction records and relevant supporting documentation becomes increasingly important.
Businesses should periodically reconcile information from sales management systems, e-commerce platforms, electronic invoices, bank accounts and accounting records to identify and address discrepancies in a timely manner.
4. Towards Greater Tax Transparency and Proactive Compliance
As highlighted in the professional perspectives shared during the interview, further development of tax administration in the digital economy should promote transparency, ensure that tax obligations reflect the actual nature of business activities and enable taxpayers to comply proactively.
In addition to providing greater clarity on tax obligations arising from different digital business models, improved data reconciliation mechanisms and early risk-warning tools could help reduce errors and lower compliance costs for businesses.
For businesses, e-commerce tax administration goes beyond tax declaration and payment. It is closely linked to the quality of accounting data, effective transaction controls and the management of operational and tax compliance risks.
KTC Tax and Accounting Advisory Services
For businesses operating across multiple digital platforms, reviewing the consistency of revenue records, invoices, cash flows and accounting data is an important part of managing tax compliance risks.
Drawing on its practical experience in tax and accounting, Russell Bedford KTC assists businesses in reviewing the recognition of revenue and expenses arising from e-commerce activities, reconciling accounting records with invoices and tax declarations, assessing compliance matters and preparing supporting documentation for tax authority enquiries or inspections where necessary.
Businesses seeking assistance with reviewing tax obligations and accounting matters related to e-commerce activities are welcome to contact Russell Bedford KTC to discuss an appropriate scope of support.
This article has been adapted and developed from the professional insights shared by Ms. Thai Thi Van Anh in an interview published by the Tax and Customs publication of the Economics and Finance Magazine (Ministry of Finance of Vietnam), with additional practical considerations relevant to businesses. Read the original interview in Vietnamese.
