Businesses Face Greater Scrutiny of Tax Records, Related-Party Transactions, Customs Data and Sector-Specific Compliance
Vietnamese regulators are strengthening corporate compliance oversight by moving away from broad, routine inspections and increasingly using risk-based management systems to identify businesses for detailed review.
Recent tax enforcement outcomes and newly announced provincial inspection programmes indicate that companies should prepare for more targeted scrutiny across taxation, transfer pricing, customs, import-export operations, chemicals, electricity, energy efficiency and other regulated activities.
The shift is particularly relevant for foreign-invested enterprises, multinational groups and businesses with complex cross-border operations, where inconsistencies between accounting records, tax filings, customs declarations and operational data may attract regulatory attention.
Tax Authorities Increasingly Rely on Digital Risk Analysis
Vietnam’s Department of Taxation has confirmed that tax administration is becoming increasingly centred on risk management and digital data analysis.
Instead of selecting taxpayers randomly, authorities are reportedly using taxpayer risk profiles to determine which businesses require inspection or examination.
During the first six months of 2026, tax inspections and examinations led authorities to recommend collections, adjustments and penalties exceeding VND 34 trillion. Regulators also reduced declared business losses and deductible value-added tax claims by substantial amounts.
The development reflects Vietnam’s wider tax administration reforms, which seek to encourage voluntary compliance while directing enforcement resources towards taxpayers considered more likely to present compliance risks.
Foreign-Invested Enterprises May Face Greater Scrutiny
Foreign-invested enterprises and multinational groups may be particularly affected by the move towards data-driven oversight.
Regulators are expected to examine areas such as:
- Related-party transactions
- Transfer pricing documentation
- Cross-border service arrangements
- Import and export values
- Deductible expenses
- VAT claims
- Declared losses
- Consistency of financial and tax data
Businesses with international operations should therefore ensure that transaction documentation, contractual terms and accounting treatment remain consistent across all regulatory filings.
Professional Internal Audit Services can help companies identify documentation gaps, control weaknesses and reporting inconsistencies before an inspection notice is issued.
Sector Regulators Also Moving Towards Targeted Inspections
Vietnam’s risk-based regulatory approach extends beyond tax administration.
Thanh Hoa province has approved a specialised inspection programme covering 87 enterprises and organisations during 2026 under the authority of the provincial Department of Industry and Trade.
The inspections will focus on compliance in areas including:
- Electricity
- Energy efficiency
- Chemicals
- Industrial explosives
- Import-export activities
- Other specialised industrial requirements
The review period will generally cover compliance from January 1, 2025 onwards.
On-site inspections are normally expected to last no more than two working days unless a longer period is required under applicable law.
Authorities have also indicated that inspection programmes should avoid unnecessary duplication with reviews conducted by other government agencies.
Regulatory Oversight Becoming More Sector-Specific
Although the Thanh Hoa programme applies to one province, it reflects a wider trend in Vietnam.
Inspections are becoming:
- More targeted
- More data-driven
- More industry-specific
- More focused on identified risk indicators
- Better coordinated across regulatory authorities
This means businesses may no longer be reviewed only through general tax or financial audits. Instead, inspections may focus narrowly on the specific regulatory obligations associated with their sector and operating model.
Businesses involved in manufacturing, chemicals, energy-intensive activities and international trade may therefore face simultaneous exposure to tax, customs, licensing and operational compliance requirements.
Compliance Information Is Increasingly Interconnected
One of the most significant developments is the increasing integration of information available to different regulators.
Tax authorities can use data from:
- Electronic invoices
- Customs declarations
- Financial statements
- Tax returns
- Licensing records
- Government databases
- Operational reports
This increased access makes inconsistencies more visible.
For example, a company’s customs declarations may be compared with its accounting records, tax filings and inventory data. Similarly, reported production volumes may be reviewed against electricity consumption, import records or sector-specific licences.
Accurate Bookkeeping Services and disciplined record maintenance are therefore becoming essential components of regulatory preparedness.
Related-Party Transactions Remain a Key Risk Area
Companies with related-party arrangements should review whether their transfer pricing documentation accurately reflects the commercial substance of their transactions.
Regulators may examine:
- Management and service fees
- Royalty payments
- Intercompany loans
- Cross-border purchases and sales
- Cost allocations
- Profit margins
- Transactions with overseas affiliates
Businesses should ensure that their contracts, invoices, transfer pricing files, tax returns and accounting records present a consistent commercial narrative.
Where documentation is incomplete or contradictory, authorities may challenge deductions, adjust taxable income or impose penalties.
Specialised Strategic Advisory can assist multinational businesses in reviewing cross-border structures and identifying compliance risks before regulatory examination.
What Businesses Should Do Now
Companies operating in Vietnam should consider strengthening compliance readiness before receiving an inspection notice.
Priority actions include:
- Reviewing tax filings and supporting documentation
- Conducting periodic internal compliance reviews
- Reconciling accounting records with customs declarations
- Testing the consistency of e-invoice data
- Reviewing related-party transactions
- Updating transfer pricing documentation
- Examining high-risk tax positions
- Organising licences and sector-specific records
- Preparing documents for rapid production during inspections
Businesses should also establish clear responsibility for regulatory compliance across finance, tax, legal, customs and operational teams.
Compliance Should Be Treated as an Ongoing Governance Function
The shift towards risk-based supervision means compliance can no longer be viewed only as an annual filing exercise.
Companies must maintain ongoing consistency between their commercial activities and the information reported to government authorities.
Businesses with stronger internal controls, reliable documentation and clear reconciliation processes are likely to be better prepared when selected for inspection.
Foreign investors should also conduct structured Business Advisory reviews before entering new transactions, changing operating models or expanding into regulated sectors.