On 30 June 2026, the Ministry of Finance issued Circular No. 89/2026/TT-BTC, providing detailed guidance on several provisions of the Law on Tax Administration 2025 and Decree No. 252/2026/ND-CP regarding amendments to Value Added Tax (VAT) declarations, effective from 01 July 2026.
Below are the key amendment scenarios that taxpayers should be aware of.
GUIDELINES FOR AMENDING VAT DECLARATIONS FROM 01 JULY 2026 UNDER CIRCULAR No. 89/2026/TT-BTC
1. Amended Declaration Increasing Unutilized Input VAT Carried Forward
(This does not apply to errors related to input VAT.)
Where errors in a previous tax period result in an increase in the amount of deductible VAT carried forward, taxpayers must:
- Submit an amended VAT return for the tax period containing the error.
- Declare the additional deductible VAT under the item:
“Adjustment Increasing Deductible VAT Carried Forward from Previous Tax Periods”
on the VAT return for the period in which the error is discovered.
2. Amended Declaration Reducing Unutilized Input VAT Carried Forward
There are three different situations:
Case 1: No VAT Refund Application Submitted
The taxpayer shall:
- Submit an amended VAT return for the affected tax period.
- Declare the adjustment under:
“Adjustment Decreasing Deductible VAT Carried Forward from Previous Tax Periods”
on the VAT return for the period in which the error is identified.
Case 2: VAT Refund Application Submitted but Not Yet Approved
The taxpayer must:
- Submit a written request to withdraw the VAT refund application.
- Reduce the amount of VAT claimed for refund.
If the remaining VAT still qualifies for deduction, it shall be declared under:
“Adjustment Increasing Deductible VAT Carried Forward from Previous Tax Periods.”
Case 3: VAT Refund Already Approved
The taxpayer must:
- Reduce the refunded VAT amount.
- Increase the amount subject to recovery by the tax authority.
- Repay the refunded amount to the State budget together with any applicable late payment interest.
If the remaining VAT still satisfies deduction conditions, it may continue to be declared under:
“Adjustment Increasing Deductible VAT Carried Forward from Previous Tax Periods.”
3. Amended Declaration Reducing Deductible VAT Carried Forward While Increasing VAT Payable
Where an error simultaneously:
- reduces deductible VAT carried forward; and
- increases VAT payable,
the taxpayer must:
- Submit an amended VAT return.
- Pay the additional VAT due.
- Pay any late payment interest as prescribed.
The remaining deductible VAT after adjustment shall be declared under:
“Adjustment Decreasing Deductible VAT Carried Forward from Previous Tax Periods.”
4. Amended Declaration Reducing VAT Payable While Increasing Deductible VAT Carried Forward
Where the amendment results in a reduction of VAT payable:
The taxpayer shall:
- Submit an amended VAT return.
- Reduce the VAT payable accordingly.
- Reduce any related late payment interest, if applicable.
- If the tax has already been paid, the excess amount may be offset against future tax liabilities or refunded in accordance with regulations.
At the same time, the increased deductible VAT carried forward shall be declared under:
“Adjustment Increasing Deductible VAT Carried Forward from Previous Tax Periods.”
5. Amendments Affecting Both VAT Return Forms 01/GTGT and 02/GTGT
Circular No. 89/2026/TT-BTC provides guidance for three situations.
Case 1
A reduction in VAT payable on Form 01/GTGT (business activities) results in a corresponding reduction on Form 02/GTGT.
The taxpayer must amend the relevant items on Form 02/GTGT.
Case 2
A reduction in input VAT of an investment project results in lower deductible VAT reported on Form 02/GTGT.
The taxpayer must:
- Adjust the corresponding items on Form 01/GTGT.
- Pay any additional VAT and late payment interest, if incurred.
Case 3
Errors on Form 02/GTGT are discovered only after the investment project has been completed.
In this situation:
- No amendment to Form 02/GTGT is required.
- Adjustments shall be made directly on Form 01/GTGT for the period in which the error is detected through the appropriate increase or decrease adjustment for deductible VAT carried forward.
6. Inherited Deductible VAT Balance
Where a business inherits deductible VAT due to:
- Demerger;
- Division;
- Merger;
- Consolidation;
- Business restructuring or conversion;
- Termination of a dependent unit,
the taxpayer shall:
- Not submit an amended VAT return.
- Declare the inherited VAT directly under:
“Deductible VAT Received Through Transfer During the Tax Period”
on Form 01/GTGT for the tax period in which the tax authority issues the transfer-of-tax-obligation notice.
Important Note
Taxpayers should ensure that all amended VAT declarations are prepared and submitted in accordance with Circular No. 89/2026/TT-BTC and other relevant legal regulations to minimize tax compliance risks during tax audits and inspections.
SUMMARY OF PENALTIES FOR LATE SUBMISSION OF VAT RETURNS IN 2026
Pursuant to Article 13 of Decree No. 125/2020/ND-CP, as amended by Clause 10, Article 1 of Decree No. 310/2025/ND-CP, penalties for late submission of VAT returns are as follows.
1. Warning
Applicable where:
- The VAT return is submitted 1–5 days late; and
- There are mitigating circumstances.
2. Fine from VND 2,000,000 to VND 5,000,000
Applicable where:
- The VAT return is submitted 1–30 days late; and
- The taxpayer is not eligible for a warning.
3. Fine from VND 5,000,000 to VND 8,000,000
Applicable where:
- The VAT return is submitted 31–60 days late.
4. Fine from VND 8,000,000 to VND 15,000,000
Applicable where:
- The VAT return is submitted 61–90 days late;
- The VAT return is submitted over 90 days late, but no VAT is payable;
- No VAT return is submitted, but no VAT liability arises; or
- Required transfer pricing documentation is not submitted together with the Corporate Income Tax finalization dossier.
5. Fine from VND 15,000,000 to VND 25,000,000
Applicable where:
- The VAT return is submitted more than 90 days late;
- VAT is payable; and
- The taxpayer has fully paid the VAT and late payment interest before the tax authority announces an inspection decision or prepares an administrative violation record.
If the calculated fine exceeds the tax payable, the maximum fine shall equal the tax payable, but not be lower than the average level prescribed for this penalty bracket.
Remedial Measures
In addition to administrative penalties, taxpayers are required to:
- Pay all outstanding late payment interest to the State budget.
- Submit all overdue tax returns and any missing schedules or supporting documents in accordance with regulations.
EXTENSION OF VAT PAYMENT DEADLINES FOR QUARTERS II & III OF 2026
On 27 June 2026, the Government issued Decree No. 245/2026/ND-CP, providing extensions for payment deadlines of Value Added Tax (VAT), Corporate Income Tax (CIT), Personal Income Tax (PIT), and Land Rental Fees in 2026.
According to Clause 1, Article 2 of Decree No. 245/2026/ND-CP, the extension period for VAT payments (including allocated VAT and VAT payable on individual taxable transactions) is up to five (05) months.
Extended Payment Deadlines
Quarter II of 2026
- Tax period: Quarter II/2026
- Extended deadline: 02 November 2026
Quarter III of 2026
- Tax period: Quarter III/2026
- Extended deadline: 30 December 2026
Important Note
The above extension does not apply to import VAT.
Businesses should review their tax obligations carefully and comply with the revised deadlines to avoid unnecessary p
enalties and interest.
