Tax Department Publishes List of 108 Enterprises for 2026 Specialized Tax Audit Plan: Which Large Enterprises Are on the List?

The Tax Department has issued Decision 446/QĐ-CT, assigning the Head of the Inspection Panel responsibility for organizing and implementing the 2026 specialized tax audit plan in accordance with current regulations. The decision takes effect on April 1, 2026, and the Head of the Inspection Panel and heads of relevant units are tasked with carrying out its provisions.

Decision 446/QĐ-CT and implementation timeline

Decision 446/QĐ-CT takes effect from April 1, 2026. The Head of the Inspection Panel, together with the heads of related units, is responsible for implementing the 2026 specialized tax audit plan of the Tax Department.

Earlier guidance on enterprises reporting losses

Before Decision 446/QĐ-CT, the Tax Department issued Official Dispatch 1927/CT-KTr dated March 31, 2026, focusing on strengthening tax management for enterprises that have reported losses for multiple years and have thin margins.

Key tasks assigned to tax authorities

• Strengthen information dissemination to all taxpayers to ensure truthful, accurate, and complete tax declarations in accordance with the law; warn of legal consequences and sanctions for cases where taxpayers repeatedly declare losses for multiple years without paying taxes while continuing to invest and expand. This is identified as a major risk factor used to include cases in targeted audit planning and to strictly address violations of tax law, tax evasion, and tax fraud.
• Strengthen discipline in tax administration, raise taxpayer compliance awareness for the 2025 tax year, and encourage self-review of prior tax periods. Where declarations are not accurate, taxpayers are expected to file adjustment declarations.
• Accelerate review of tax declarations and payments by enterprises. If errors are found, tax authorities are required to provide full guidance to enable enterprises to declare and adjust promptly, and to strengthen on-site inspections.
• For enterprises listed in Appendix I, the Large Enterprise Tax Bureau and provincial tax departments directly develop specialized audits at the taxpayer’s headquarters for companies with long-standing losses and thin margins. If an audit at the taxpayer’s premises is not possible, the tax department must report the reasons.

List of high-risk enterprises for 2026 specialized audits

The Tax Department has reviewed and compiled a list of enterprises with annual revenue of 1,000 billion VND or more that recorded losses for two consecutive years (2023 and 2024), with details provided in Appendix II. The Tax Department requests provincial tax departments, the Large Enterprise Tax Bureau, and the Electronic Commerce Tax Department to review the list and update business performance data based on 2025 corporate income tax finalization to identify high tax-risk enterprises and include them in the 2026 specialized topic plan.

The document also notes that the list comprises 108 enterprises.