Executive summary

Decree 252/2026/ND-CP (Decree 252), dated 30 June 2026, provides detailed guidance on business activities that foreign suppliers conduct on e-commerce and digital platforms, including:

• Definitions and criteria for e-commerce platforms and digital platforms with online ordering and payment functions
• Taxpayers, including foreign suppliers and organizations responsible for withholding and paying taxes on behalf of foreign suppliers
• Tax registration requirements
• Tax declaration dossiers
• Other obligations

Definitions and criteria for platforms with online ordering and payment functions

E-commerce and digital platforms are considered to have online ordering and payment functions if they meet the following criteria:

1. They enable buyers to select goods or services and conclude transactions with sellers through the platform.
2. They directly or indirectly participate in the payment process, with the ability to control, reconcile or confirm payment transactions, including collecting payments from buyers and transferring them to sellers or coordinating such processes with other parties; they organize payment mechanisms if the completion of a transaction is tied to payment confirmation on the platform.
3. The determination of whether a platform has payment functionality is based on its actual role in organizing, controlling or participating in the payment process, regardless of the technical form or payment method used. Platforms that only provide listing, advertising or transaction-matching services without involvement in the payment process are excluded from this scope.

E-commerce and digital platforms with payment functions are defined as digital platforms that meet criteria (2) and (3) mentioned above.

Taxpayers

Direct taxpayers are defined as foreign organizations and individuals conducting business on e-commerce or other digital platforms that are responsible for fulfilling their tax obligations in accordance with applicable tax laws.

Withholding agents include:

• Vietnamese companies purchasing services from foreign suppliers
• Foreign digital platform operators that withhold and remit taxes on behalf of foreign suppliers
• E-commerce and digital platform operators with payment functions that withhold, declare and remit taxes on behalf of household businesses and individuals operating on their platforms
• Other platform operators/owners (domestic or foreign) with both ordering and payment capabilities that withhold, declare and remit taxes on behalf of household businesses and individuals operating on their platforms

Tax registration and declaration

In relation to business activities conducted through e-commerce and digital platforms, Vietnam's tax framework adopts a multi-layer collection mechanism under which tax obligations may be fulfilled through different collection channels depending on the nature of the transaction.

Withholding by Vietnamese purchasers (business-to-business transactions)

For cross-border transactions in which Vietnamese organizations purchase goods or services from foreign suppliers or nonresident individuals, the Vietnamese purchaser is obligated to withhold, declare and pay value-added tax (VAT), corporate income tax (CIT) and/or personal income tax (PIT) at the time of payment.

Vietnam-based business organizations must declare withheld taxes on a transaction-by-transaction basis; however, if transactions occur frequently, monthly declaration is permitted.

If the Vietnamese purchaser has fully withheld and paid taxes due, the foreign supplier is not required to separately declare and pay taxes in respect of the same income. In this case, the Vietnamese business purchaser must electronically notify the platform operator so that the platform does not withhold taxes again on the same transaction. The notification must include following information: tax code of the withholding entity, transaction/order number, transaction value, taxes withheld and remitted, and information of the seller/service provider. Both the Vietnamese purchaser and the platform operator are required to retain relevant records and supporting documents and provide them to the tax authorities upon request.

Withholding by e-commerce and digital platform operators/owners

If tax withholding is not performed by a Vietnamese purchaser, e-commerce and digital platform operators/owners with online ordering and payment functionalities (whether domestic or foreign) may be required to act as withholding agents.

Platform operators are required to:

• Withhold, declare and pay taxes on behalf of household and individual sellers, including:
  • VAT on domestic transactions
  • PIT on domestic and overseas transactions of Vietnamese tax-resident sellers
  • PIT on domestic transactions of nonresident individual sellers
• Withhold, declare and pay VAT and CIT on behalf of foreign suppliers

The tax obligation arises when the platform confirms completion of the transaction and payment in accordance with its operating rules.

If the platform operator/owner has fully withheld and paid taxes due, the underlying sellers or foreign suppliers are relieved from direct tax filing obligations for those transactions.

Platform operators/owners are required to file monthly tax declarations for taxes withheld. For canceled or returned transactions, the withheld taxes may be offset against taxes payable on other transactions.

Direct tax registration, declaration and payment by foreign suppliers

If taxes are not withheld and paid by either a Vietnamese purchaser or a platform operator/owner, foreign suppliers are required to directly register, declare and pay taxes in accordance with Vietnam's tax regulations.

Tax declaration and payment obligations for foreign suppliers are determined based on business frequency:

• Foreign suppliers with regular business activities in Vietnam: Monthly tax declaration and payment
• Foreign suppliers with non-recurring activities: Tax declaration and payment on a transaction-by-transaction basis, for each instance of income arising in Vietnam

Obligations of relevant parties

Platform operators/owners responsible for withholding and remitting taxes must:

• Manage tax authority-issued accounts and retain transaction data and supporting documents for tax determination
• Withhold, declare and remit taxes accurately and fully based on information provided by foreign suppliers, businesses and individuals
• Provide relevant information to tax authorities upon request
• Timely refund withheld taxes relating to canceled or returned transactions
• Comply with other obligations in accordance with regulation

Foreign suppliers earning income from Vietnam that has not been withheld by Vietnamese organizations or platform operators must:

• Directly register, declare and pay taxes via the tax authority's system
• Provide accurate, complete and timely information to support tax determination
• Retain relevant information used to identify transactions of Vietnamese customers for tax inspection purposes
  • This includes bank accounts, payment accounts, e-wallets and other payment methods used to receive funds from Vietnamese customers or e-commerce platform operators. The registration information must include details of the financial institution or payment service provider, country of account opening, account number (or account identifier), account holder name and currency denomination.
• Review and confirm the accuracy and completeness of declared payment account information when changes occur
  • This confirmation must be submitted via the tax authority's system, together with the December tax filing. No confirmation is required if there are no changes.

Implications

Foreign suppliers should review their existing arrangements with Vietnamese customers and platform operators in light of the new withholding and notification requirements. Early coordination among the relevant parties may be important to ensure proper implementation of the new rules and to address the risk of duplicate tax withholding and reporting inconsistencies.