Circular No. 90/2026/TT-BTC: 03 new cases subject to tax registration from July 1, 2026

-Notably, Clause 2, Article 4 of Circular No. 90/2026/TT-BTC adds three new cases subject to direct tax registration with tax authorities. These cases are all associated with e-commerce, the digital economy, and the global minimum tax.

1. Non-resident individuals doing business on e-commerce platforms

Under Point e, Clause 2, Article 4 of Circular No. 90/2026/TT-BTC, non-resident individuals conducting business on e-commerce platforms that do not have online ordering and payment functions are required to carry out tax registration directly with tax authorities.

This is an entirely new regulation. Previously, Circular No. 86/2024/TT-BTC only generally provided for foreign suppliers and non-resident foreign individuals conducting e-commerce business activities, without separately classifying non-resident individuals according to different digital platform business models.

2. Domestic operators of e-commerce platforms

Under Point h.3, Clause 2, Article 4 of Circular No. 90/2026/TT-BTC, operators of domestic e-commerce platforms and other digital platforms with online ordering and payment functions must register for tax to obtain a tax identification number for:

- Withholding tax;
- Declaring tax;
- Paying tax on behalf of:

• Foreign suppliers;
• Business households;
• Business individuals.

Under Circular No. 86/2024/TT-BTC, the responsibility for withholding and paying tax on behalf of taxpayers mainly rested with commercial banks, payment intermediary service providers, or organizations authorized by foreign suppliers. No such responsibility was imposed on operators of e-commerce platforms.

3. Organizations declaring the global minimum tax

Under Point o, Clause 2, Article 4 of Circular No. 90/2026/TT-BTC, organizations declaring and paying additional corporate income tax (CIT) in accordance with regulations on the global minimum tax are also required to carry out direct tax registration with tax authorities.

This regulation had not previously been provided for in Circular No. 86/2024/TT-BTC.

- Foreign suppliers;
- Foreign contractors;
- Organizations responsible for withholding and paying tax on behalf of taxpayers;
- Petroleum contract operators;
- Other organizations and individuals subject to direct tax registration.
 

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