The setup: 9am Monday, the company receives a tax audit decision — the team arrives in 3 working days. The director calls the chief accountant: “what do we do now?” The chief accountant hesitates — and the golden 48 hours dissolve into chaos. A tax audit isn’t a surprise accident — it’s a process with rules (Tax Administration Law 108/2025/QH15). Whoever prepares well in the first 48 hours holds the initiative for the entire audit.
10 things to do in the first 48 hours
1. Read the audit decision carefully. Scope (which taxes), audit period (which years), legal basis — anything outside scope is off-limits.
2. Set up an internal task force. One single liaison with the audit team; assign owners per tax type.
3. Hire advisers now. Lawyers/accountants experienced with audits — the earlier the better; don’t wait for the team to arrive.
4. Preserve documents — never destroy. Destroying or altering records after receiving the decision is an aggravating circumstance, potentially criminal.
5. Reconcile books against returns. Self-review revenue, cost and input-VAT gaps — know your weaknesses before the team does.
6. Prepare transfer-pricing files. Local File, Master File — every FDI audit asks for them.
7. Review limitation periods. Periods past the statute of limitations for penalties/collection — note them; not everything is still “claimable”.
8. Prepare workspace for the team. A separate room, printer, support staff — cooperation builds goodwill; obstruction only worsens things.
9. Brief staff: who says what. Only the liaison speaks; others don’t volunteer explanations — inconsistent statements become evidence against the company.
10. Build a timeline and request extensions in writing. Know each document deadline; if time is short, request extension in writing instead of silence.
Four fatal mistakes
1. Destroying/altering records — from administrative violation to criminal signal.
2. No advisers — facing a professional team alone is a gamble.
3. Volunteering out-of-scope documents — oversharing invites wider scrutiny; provide only what’s within the decision’s scope.
4. Signing minutes unread — every signature has legal force; record reservations when disagreeing.
Frequently asked questions
1. How soon does the team arrive after the decision?
Per the decision — usually a few working days; use the time to prepare per the 10 items above, don’t wait.
2. Can we refuse to provide documents?
No refusal for in-scope documents — but you may decline (in writing, with reasons) documents outside the decision’s scope.
3. Should we hire a lawyer from the start?
Yes — early advisers shape scope and explanation strategy; hiring after a violation record is half too late.
4. Can the audit scope be narrowed?
The decided scope can’t shrink — but clean files and convincing explanations help the team finish early without expanding to other periods.
5. How long does a tax audit usually take?
Weeks to months depending on scale and complexity; good cooperation and complete files shorten it significantly.
This article has been quality-reviewed by the FLAW AI Legal Council.
