Enterprises subject to tax inspections and examinations in 2025

Following the 2025 Inspection Program orientation under Official Letter No. 2220/TTCP-KHTH dated 23 October 2024 by the State Inspectorate, the General Department of Taxation and the General Department of Customs will conduct tax inspections and examinations of the following groups of enterprises in 2025:

1. The General Department of Taxation:

1. Enterprises operating in industries and sectors with significant potential tax risks, including oil and gas, petroleum, electricity, telecommunications, banking, insurance, securities, financial leasing, pharmaceuticals, real estate, construction, gold, silver, and gemstone processing, entertainment, advertising, and e-commerce;
2. Large-scale enterprises that have not undergone tax inspections or examinations for several years;
3. Enterprises involved in capital transfers, brand transfers, or project transfers;
4. Enterprises issuing securities that distribute dividends as shares, or pay bonus shares;
5. Enterprises engaged in related-party transactions, transfer pricing, or reporting losses for several consecutive years, or whose business results are significantly lower than those of other enterprises in the same industry or sector;
6. Enterprises benefiting from tax incentives or claiming tax relief or reductions under Double Taxation Agreements; and
7. Enterprises with other potential tax risks.

2. The General Department of Customs will conduct specialized inspections of enterprises engaged in the following activities:

1. Import of goods with high tax rates and substantial import turnover, focusing particularly on goods with a sudden increase in turnover or indications of fraud related to classification codes, values, origins, or regulatory policies. Examples include raw and ancillary materials for the garment industry, electronic components, and machinery;
2. Import of goods with indications of fraud in quality, safety, or food hygiene standards, such as beverages, cigarettes, functional foods, and cosmetics;
3. Import of goods with indications of fraud in value, tax rates, or compliance with state management policies, including minerals, mineral-based products, timber, and iron and steel;
4. Import of raw materials for processing, production, and export, particularly where there is significant import-export turnover or a sudden increase in turnover;
5. Import of goods intended for investment projects;
6. Import of components for the assembly and production of automobiles eligible for tax incentives;
7. Foreign-invested export processing enterprises engaged in business activities beyond authorized export processing activities; and
8. Enterprises exhibiting other customs-related risks.

Enterprises in these groups should review their tax and customs dossiers, promptly supplement any missing documents, and ensure that all relevant documents are properly archived to mitigate the risk of tax reassessment during inspections and examinations by the tax and customs authorities.

Disclaimer: This publication is for general update. This should not be construed as professional advice for any specific case, entity, or individual. If you require further information or professional assistance concerning your specific circumstances, please feel free to contact us.

Dentons LuatViet acknowledges and thanks Trainee Associate Giang Nguyen for her contribution to the article.

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