Article 48 of the 2025 Tax Administration Law stipulates the cases of being subject to enforcement of administrative decisions on tax management from July 1, 2026 as follows:
- Taxpayers with tax arrears exceeding 90 days from the date of expiration of the payment period as prescribed.
- Taxpayers who have tax debts when the tax payment extension period expires.
- Taxpayers who have tax arrears but do not operate at the registered address or have acts of asset diversion.
- Taxpayers do not comply with the decision to sanction administrative violations of tax management according to the time limit stated on the decision to sanction administrative violations of tax management, except in cases of postponement or temporary suspension of the enforcement of the sanctioning decision.
- Taxpayers who have been administratively sanctioned for failing to comply with tax inspection decisions but continue to fail to comply with tax inspection decisions.
- Not yet implementing tax coercive measures for taxpayers' debts that the tax management agency does not charge late payment fees according to regulations; are allowed to gradually pay tax debts within a period of no more than 12 months from the date the competent authority issues a document accepting gradual payment of tax debts and within the time the guarantee letter takes effect. The gradual payment of tax debts is considered by the head of the tax management agency based on the request of the taxpayer and must have a guarantee from a credit institution.
- Not implementing coercive measures against taxpayers who owe customs fees and fees for goods and means of transport in transit.
- The tax authority does not implement coercive measures against the amount of tax debt compensated through tax refunds that the tax authority is carrying out procedures to compensate taxpayers.
- The Head of the tax management agency shall decide on the basis of the actual situation to implement coercive enforcement of administrative decisions on tax management.
