Article 22, Section 6 of the 2025 Tax Administration Law (Law No. 108/2025/QH15) details tax inspection.
Accordingly, the tax authority will conduct tax inspections at the taxpayer's headquarters in the following cases:
- Cases where the dossier is subject to pre-refund inspection
- In case the dossier is subject to post-refund inspection for dossiers subject to pre-refund according to the principle of risk management in tax management and within 05 years from the date of issuance of the tax refund decision
- Cases with signs of law violations in the field of taxation
- Cases selected according to plan, topic
- In cases according to the requirements and requests of agencies and competent persons. Taxpayers with high risks fall into the cases of: division, separation, merger, consolidation, conversion of enterprise type, bankruptcy, dissolution, termination of operations, equitization, termination of tax code validity, relocation of business location.
- In cases specified in point b, clause 2 of this Article. Specifically, when inspecting taxes at the headquarters of the tax management agency, the tax management agency has the right to request taxpayers to explain and supplement information and documents; issue tax determination decisions, handle administrative violations of tax management or transfer to inspection at the taxpayer's headquarters.
- In case of inspection at the request of resolving complaints and denunciations about taxes
- In cases where tax exemption, tax reduction, and tax non-collection dossiers of taxpayers are at high risk
The 2025 Law on Tax Administration also stipulates that customs authorities inspect taxes at taxpayers' headquarters in cases specified in point a of this clause; post-customs clearance inspections shall be carried out in accordance with the provisions of customs law; inspection of conditions for applying tax policies shall be carried out in accordance with the provisions of relevant laws. During the inspection process, customs authorities shall conduct actual inspections of exported goods and imported goods in cases of necessity and sufficient conditions.
For cases selected according to plans, topics and cases of division, separation, merger, consolidation, conversion of business types, bankruptcy, dissolution, cessation of operations, equitization, termination of tax code validity, business location relocation, the tax authority shall conduct inspections at the taxpayer's headquarters no more than 01 time in 01 year. This regulation does not apply to cases of re-inspection specified in point a, clause 6 of this Article.
The tax inspection period is no more than 20 days from the date of announcement of the inspection decision, if necessary, it can be extended once but not more than 20 days.
The tax inspection period for businesses with related transactions is no more than 40 days, if necessary, it can be extended once but not more than 40 days.
In case it is necessary to collect and exchange information with foreign tax authorities, the tax inspection period may be extended but not exceeding 02 years.
The inspection period specified at this point does not include the time of temporary suspension of inspection according to the notice of the tax management agency.
