Tax Record Keeping for Companies in Vietnam

Why record keeping determines inspection outcomes

In tax inspections and examinations, the burden of proof lies with the company. Tax authorities are not obligated to believe explanations — they only recognize what is shown in valid records and vouchers. The following three scenarios show how stored records directly determine the amount a company must pay:

First, deductible expenses for CIT purposes. An expense is deductible only when simultaneously meeting the conditions: actually incurred, related to production and business activities, and supported by complete lawful invoices and vouchers. Without presentable invoices and vouchers — even if the expense is real — the expense is disallowed and the company is assessed back tax on the difference.

Second, creditable input VAT. A company may credit input VAT only with lawful VAT invoices and non-cash payment vouchers for invoices of VND 5 million or more. Losing invoices means losing the right to credit.

Third, special tax positions: tax incentives being enjoyed, transfer pricing documentation, VAT refund files. These records must not only “exist” but be complete and consistent — a thin transfer pricing file is worth little more than no file when tax authorities question pricing.

What to keep: the tax records checklist

The minimum checklist an FDI enterprise should keep in full:

Returns and tax payment vouchers. VAT, CIT (provisional and final), PIT, contractor tax, and business license fee returns across periods; state budget payment slips; tax authority confirmations of tax obligations.

Invoices and accounting vouchers. Input and output e-invoices; payment vouchers (payment orders, bank statements); receipts and disbursement slips; economic contracts underlying transactions.

Books and reports. Detailed and general ledgers; annual audited financial statements (if subject to audit); tax finalization reports.

Special tax files. Transfer pricing documentation (prepared before the annual CIT finalization deadline under Decree 255/2026/ND-CP); VAT refund application files and refund decisions; files proving eligibility for CIT incentives; Certificates of Residence and DTA application files (if any); tax inspection and examination minutes and authorities’ decisions over the years.

Tax-related personnel files. Labor contracts, payrolls, PIT finalization for employees — especially for foreign experts, work permits and residence-time evidence should also be kept to determine PIT obligations.

How long to keep: statutory retention periods

Accounting document retention periods are prescribed in the 2015 Law on Accounting (Law 88/2015/QH13) with detailed guidance in Decree 174/2016/ND-CP. Periods are computed from the end of the annual accounting period.

Minimum 10 years for accounting documents directly used as the basis for tax declaration and computation, bookkeeping, and financial statement preparation. This group includes: accounting vouchers (invoices, receipts and disbursement vouchers), detailed and general ledgers, monthly/quarterly/annual financial statements, finalization reports, and asset inventory minutes. In other words, the company’s entire core tax records fall into the 10-year group.

Also in the long-retention group are accounting documents related to establishment, division, separation, consolidation, merger, enterprise type conversion, dissolution, and bankruptcy — and inspection and examination files of competent state authorities. For FDI enterprises, this means records of the entire restructuring and capital transfer processes must also be kept in full.

Minimum 5 years for accounting documents used for the unit’s management and administration that do not directly serve as the basis for bookkeeping and financial statement preparation — e.g., quotations, purchase orders, internal administration documents.

Important note: these periods are minimums. If another specialized law prescribes a longer period, that law applies. For cases under tax complaint, litigation, or inspection/examination, related records must be kept until the case is finally resolved — no destruction during this time. The 2025 Law on Tax Administration (Law 108/2025/QH15, effective 01/7/2026) may adjust some related obligations — companies should monitor guiding documents when the law takes effect.

In what form: paper and electronic

The law does not require all records to be kept on paper. The current trend is electronic storage, but conditions must be met for electronic vouchers to have legal value equivalent to paper.

E-invoices. Under Decree 254/2026/ND-CP, e-invoices are stored by electronic means. Companies need to ensure their e-invoice storage system meets lookup and reconciliation requirements when tax authorities request — not just storing PDF files but also the original invoice data in the prescribed format.

Electronic vouchers and books. Ledgers and financial statements prepared on accounting software need periodic backups ensuring data integrity. When changing accounting software or service providers, there must be a data conversion and legacy data storage plan — in practice many companies lose all prior-year accounting data simply by switching software without backup.

Paper. Documents with handwritten signatures and seals (original contracts, minutes, state authority decisions) should still be kept on paper alongside scanned copies. Scans are quick lookup tools; paper is the basis when authenticity disputes arise.

General principle: regardless of form, the storage system must ensure three elements — completeness (no missing periods or types), retrievability (finding a transaction’s records within a reasonable time during inspection), and security (against loss, damage, and unauthorized access).

Consequences of failing to present records

The most serious consequence is imposed tax assessment. Under tax administration law, tax authorities may impose the tax payable when a company cannot present accounting books and vouchers, or when book figures are incomplete or inaccurate. When imposing, tax authorities determine the tax payable based on data of same-industry, same-scale companies — and this figure is almost always less favorable than the company’s actual figures.

In addition, failure to keep or present records upon request may be administratively penalized for tax violations under Decree 125/2020/ND-CP. Where fraud is indicated — e.g., destroying records to conceal tax obligations — criminal liability for tax evasion may also be considered.

A less-noticed but very practical consequence: in enterprise acquisitions and mergers, the buyer assesses the quality of tax record keeping as an indicator of risk level. Messy, deficient records are grounds for the buyer to demand price reductions or tighter tax indemnity clauses. See our article on tax due diligence in M&A transactions.

Checklist for organizing tax record keeping

For the storage system to work in practice — not just look good on paper — companies should implement these steps:

1. Classify and standardize the checklist. Build the company’s standard tax records checklist (based on Section 2 of this article), specifying which department is responsible for each record type, where it is stored, and how long.

2. Digitize and back up. Scan all important paper records; back up electronic data periodically with at least one copy outside the main system (offsite backup). Periodically test that old archived files can still be opened and read.

3. Handover procedures. When changing the chief accountant, tax personnel, or accounting service providers, a complete records handover minute is required. Many record losses occur at this handover stage.

4. Periodic internal checks. Annually, self-check a sample of prior-year records: still complete, quick to retrieve, any gaps. Detect early to supplement, rather than discovering when the inspection team has arrived.

5. Destruction rules. Destroy accounting documents only after the minimum retention period has expired and they are not under inspection, examination, complaint, or litigation. Destruction requires minutes as prescribed.

For overall tax compliance advice, see our tax consulting services for FDI enterprises and our article on tax compliance for FDI enterprises.

How FLAT LAW FIRM assists

FLAT LAW FIRM assists companies in reviewing their current tax record keeping systems: assessing checklist gaps against regulations, advising retention periods for each document type, building record storage and handover procedures, and assisting with record preparation during tax inspections and examinations. In M&A transactions, we assess the target company’s tax record keeping quality as part of tax due diligence.

See also: Tax consulting for FDI enterprises | Preparing for tax inspections at enterprises | Corporate tax compliance calendar | Contact

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