VAS bookkeeping, statutory financial statements, parent reporting reconciliation and an outsourced chief accountant for foreign-invested companies in Vietnam, updated for Circular 99/2025/TT-BTC.
Part of Viettonkin's Accounting and Tax services
Including 102,300 companies that resumed operations, Vietnam's newly registered and returning enterprises reached 297,500 in 2025. From the 2026 financial year, companies that followed the general enterprise accounting regime, including most foreign-invested operating companies, keep their books under a rewritten regime, and many are still working out what that means for their chart of accounts.
Accounting in Vietnam is a statutory obligation before it is a management tool. The Law on Accounting requires the records to be kept in Vietnamese script with Vietnamese dong as the default accounting currency, requires annual financial statements to be signed by the person who prepared them, the chief accountant and the legal representative, and requires them to be submitted to the competent authorities within 90 days of the end of the accounting year. The figures in those books then drive the value added tax return, foreign contractor tax withholding and the corporate income tax finalisation, so an error in the ledger rarely stays in the ledger.
For a foreign-invested enterprise the difficulty is that two frameworks run at once. The parent reports under IFRS, US GAAP or its own national standards; the Vietnamese entity reports under Vietnamese Accounting Standards. The two differ on the structure of the statements and on the treatment of a range of transactions, and the group needs figures it can consolidate while the local entity needs books that an auditor and a tax inspector will accept.
On 1 January 2026 the local side of that equation changed. Circular 99/2025/TT-BTC replaced Circular 200/2014/TT-BTC as the enterprise accounting regime, renamed the balance sheet, and gave companies room to adapt the chart of accounts and design their own vouchers and books, in return for documented internal accounting regulations that support those choices. It suits groups with an established parent chart of accounts better than the old regime did, and it makes the first year a larger documentation exercise.
Vietnamese Accounting Standards were written for statutory reporting and for tax, and the books are read closely by the authorities that rely on them. That is why the local ledger cannot simply be a translation of the group ledger.
The accounting records are the starting point for every tax return, and a tax examination works backwards: from the return to the ledger, and from the ledger to the source documents behind it, such as the invoice, the contract, the customs declaration and the bank statement. Where that chain breaks, the adjustment usually lands on the tax side, and it is calculated on the period in which the original entry was made rather than the period in which the problem was found.
Source documents therefore carry more weight than they do in many home markets. Input value added tax is creditable only against a valid invoice, and under the value added tax law in force since 1 July 2025 a purchase of VND 5 million or more needs evidence of non-cash payment before its input tax can be credited, down from VND 20 million under the previous law. An expense claim that would pass an internal review in the parent's jurisdiction can still fail the Vietnamese test, so document review is a monthly control rather than a year end tidy up.
Retention periods are long as well. The Law on Accounting requires accounting documents used directly to record transactions and prepare the financial statements to be kept for at least ten years, and other accounting documents for at least five. For a subsidiary whose finance function sits in a regional hub, deciding where those records are kept, and in what form, is part of setting up the accounting rather than a question to answer when an auditor first asks for an original.
The new regime took effect for financial years beginning on or after 1 January 2026. These five changes are the ones that alter the day to day work of a foreign-invested company's accounting function.
Circular 99/2025/TT-BTC was issued on 27 October 2025 and took effect on 1 January 2026, replacing Circular 200/2014/TT-BTC. It governs accounting vouchers, accounts, books and the preparation and presentation of financial statements for enterprises generally, with credit institutions following the State Bank's rules for their specific banking operations, so it reaches every foreign-invested company that followed the previous regime.
The primary statement has been renamed the statement of financial position, bringing the terminology closer to international practice. The substance of the reporting obligation is unchanged, but every reporting template, mapping file and audit working paper built around the old statement needs to be revisited in the first year under the new regime.
Enterprises may now add accounts and amend the names, codes and content of the prescribed accounts to suit their operations, provided the changes are set out in internal regulations. For a subsidiary this is the most useful change in the circular, because it allows a local chart of accounts that follows the parent's reporting structure more closely.
The circular introduces account 215 for biological assets and a detailed account, 82112, for the supplementary corporate income tax expense arising under the global minimum tax rules. Groups within the scope of those rules need the account in use from the first period in which a top-up tax expense is recognised.
Companies may design their own voucher forms and accounting book templates, as long as the records remain truthful, verifiable and traceable. The flexibility comes with a stronger expectation of written accounting policies and internal controls, and that documentation is where most of the transition work for 2026 actually sits.
Vietnamese law assigns the accounting function to a named, qualified individual, and the role cannot be filled by job title alone. It is also one of the requirements most often overlooked in a company's first year.
The Law on Accounting 88/2015/QH13 and Decree 174/2016/ND-CP require an enterprise to appoint a chief accountant, with limited exceptions: a micro enterprise may assign a person in charge of accounting instead, and a newly established company may do the same during its first twelve months. A foreign-invested operating company should plan for a qualified appointment from the outset rather than rely on the transitional window.
The law sets standards of professional ethics, an accounting qualification at intermediate level or above, a chief accountant training certificate and a minimum period of practical accounting experience that depends on the level of qualification held. A capable internal finance manager trained in the parent's framework does not automatically meet them.
Annual financial statements are signed by the person who prepared them, the chief accountant and the legal representative of the company. The signature carries responsibility for the accounting information presented, which is why the role cannot sensibly be treated as a formality delegated to whoever happens to be available at year end.
The Law on Accounting allows a company to engage an accounting service business to keep its books or to provide a chief accountant, provided the individual meets the statutory standards and the responsibilities of each party are set out in a written contract. This avoids building a local headcount around a single statutory role and removes the gap that opens when an employee in that role resigns.
The engagement is organised around the monthly close and the annual statutory cycle. The table shows who does what, because the division of responsibility is agreed before the first period is processed.
Scroll the table horizontally on smaller screens.
| Workstream | What we do | What we need from you |
|---|---|---|
| Source documents | Collect and review invoices, contracts, bank statements, customs declarations, expense claims and payroll summaries, and flag any document that will not support a deduction or an input tax credit. | Documents from suppliers and internal teams by the agreed monthly cut off, and answers to queries on unusual items. |
| VAS bookkeeping | Record every transaction in the local accounting software, covering the general ledger, receivables, payables and the fixed asset register, and complete the period end closing entries. | Approval of the accounting policies and of any judgement area identified during the close. |
| Bank reconciliation | Reconcile every Vietnamese bank account to its statement each month and investigate the differences. | Bank statements, or read access where the bank provides it. |
| Parent reporting bridge | Maintain a standing mapping between the group chart of accounts and the local chart, and prepare VAS figures from the journal entry listing your group finance team provides. | The monthly journal entry listing and advance notice of any change to the group chart of accounts. |
| Statutory books and records | Maintain the accounting books the regime requires and retain the records for the statutory periods after each year closes. | Agreement on where physical originals are kept. |
| Financial statements and audit | Prepare the annual VAS financial statements and act as the auditor's counterpart throughout the statutory audit. | Appointment of the auditor and signature by the legal representative. |
| Chief accountant | Provide a qualified chief accountant who meets the statutory standards and signs in that capacity. | A written engagement that sets out the responsibilities of each party. |
Most groups do not want a second accounting system in Vietnam. The practical answer is a disciplined mapping between the frameworks, not a parallel ledger kept by hand.
Where the group books transactions in its own enterprise system, the Vietnamese statutory ledger can be produced from the group's journal entry listing through a chart of accounts mapping agreed between the group finance team and the local accountant. The mapping is maintained as a controlled document: every group account has a local destination, every exception is written down, and a change on either side is dealt with before the period it affects rather than discovered at the close.
The mapping is not a mechanical translation. Some items are recognised differently under Vietnamese standards, some expenses that are ordinary for the group are not deductible locally, and some local requirements have no equivalent line in the group chart. Those items are identified once, recorded in the accounting policies and then handled the same way every month, so that the Vietnamese statements reconcile to the group's figures through a short list of explained differences.
Circular 99 makes this easier than it was. Because companies may now adapt the local chart of accounts within documented internal regulations, the local structure can follow the group's own more closely, which shortens the bridge and makes it easier for a regional controller to review. The first year under the new regime is the natural moment to redesign the mapping rather than carry the old one forward unchanged.
The same service looks different depending on where a company is in its life in Vietnam. These are the situations in which clients most often come to us for it.
A newly licensed subsidiary needs accounting policies, a chart of accounts, accounting software set up and a chief accountant arrangement before its first period closes. Establishing those correctly at the start is considerably simpler than restating a year of transactions later.
Where the parent needs consolidated figures under its own framework and the Vietnamese company needs statutory books, a standing mapping allows the local VAS books to be produced from the group's own journal entries without a second accounting system being maintained in Vietnam.
Accounting policies, the chart of accounts, reporting templates and internal accounting regulations all need updating for the first financial year under the new regime. The update is best done before the first quarter closes, so that comparatives and opening balances are mapped consistently.
Where books have fallen behind or been kept without a full reconciliation, they are brought to a standard an auditor can work with, and the audit is then supported through to signed financial statements.
Each legal entity in Vietnam is a separate accounting and tax unit with its own books, statements and filings. Applying the same accounting policies and mapping across the entities keeps the group picture consistent, while each entity's statutory documents are still prepared and signed on its own account.
In Vietnam the accounting records and the tax returns are two views of the same transactions. Keeping them with one team removes a reconciliation that otherwise has to be done after the fact.
Value added tax, foreign contractor tax and corporate income tax are all prepared from the accounting records. When the same team records a transaction and prepares the return that depends on it, the tax treatment is considered when the entry is made rather than rediscovered at year end.
In our engagements the chief accountant's scope covers the accounting, the bookkeeping and the value added and foreign contractor tax positions that flow directly from the books. Payroll, personal income tax and corporate income tax finalisation are scoped under the payroll and tax compliance engagements, so it is always clear who prepares each filing.
An audit adjustment that never reaches the tax position, or a tax adjustment that never reaches the books, is exactly the kind of inconsistency an examination looks for. Keeping accounting and tax in one engagement means both are explained from the same working papers.
The value added tax, corporate income tax and tax administration rules all changed between July 2025 and July 2026, and the business licence fee was abolished from 1 January 2026. Each of those changes has an accounting consequence, and they are reflected in the ledger in the period they take effect.
Since 2009, Viettonkin has supported 2,000+ businesses, including Fortune 500 and VNR500 companies. In the engagements below, accounting and tax work formed part of a wider mandate for the client.
A Canadian corporation established a legal entity in Vietnam for an aircraft components production line. The engagement extended to factory rental, staff recruitment and accounting and tax procedures, with Viettonkin acting as legal representative and dealing with the accounting and tax requirements.
Read the case study
A Singaporean investor set up a medical firm in Hanoi and acquired a local business. Viettonkin advised on the compliance procedures and supported the transition of contracts, human resources, tax and internal processes.
Read the case study
A Singaporean company with an established presence in Southeast Asia and America sought advice on dissolving a business. Viettonkin proposed the approach for the dissolution together with the payroll administration, accounting and tax work that has to be completed alongside it.
Read the case studyPractical answers on the 2026 accounting regime, the chief accountant and parent reporting.
Circular 99/2025/TT-BTC replaced Circular 200/2014/TT-BTC as the enterprise accounting regime for financial years beginning on or after 1 January 2026. The balance sheet was renamed the statement of financial position, companies may adapt the chart of accounts and design their own vouchers and books within documented internal regulations, and new accounts were added, including 215 for biological assets and 82112 for the global minimum tax expense.
Most do. The Law on Accounting and Decree 174/2016/ND-CP require an enterprise to appoint a chief accountant who meets statutory standards, with exceptions for micro enterprises and for a newly established company during its first twelve months, which may assign a person in charge of accounting instead.
Yes. The Law on Accounting allows a company to engage an accounting service business to provide a chief accountant, provided the individual meets the statutory standards and the responsibilities of each party are set out in a written contract. This is a common arrangement for foreign-invested companies that do not want to build a local finance headcount around the role.
Yes, through a chart of accounts mapping agreed with your group finance team. We prepare the VAS books and statements from the journal entry listing the group provides, handle the items that are treated differently under Vietnamese standards, and document the differences so the local statements reconcile to the group figures.
Under the Law on Accounting, documents used directly to record transactions and prepare the financial statements are kept for at least ten years, and other accounting documents for at least five years. Some records of lasting significance must be kept permanently.
Regulatory points checked on 17 September 2026; market statistics checked on 11 September 2026. Requirements depend on the entity, its activities and the period concerned.
Tell us how your group records transactions today, which framework the parent reports under and where the Vietnamese books sit. We will map what the statutory side requires under Circular 99 and how the monthly cycle would run.
