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Under Point dd, Clause 2, Article 4 of Circular No. 90/2026/TT-BTC, foreign suppliers that are foreign organizations generating revenue in Vietnam through e-commerce activities, as prescribed in Clause 1, Article 40 of Decree No. 252/2026/ND-CP, are subject to direct tax registration with the tax authorities. However, the Circular supplements the following provision:
"Foreign suppliers are not required to carry out tax registration procedures if all revenue generated in Vietnam has been subject to tax withholding and tax payment on their behalf."
Previously, Point e, Clause 2, Article 4 of Circular No. 86/2024/TT-BTC only provided that foreign suppliers without a permanent establishment in Vietnam were subject to direct tax registration with tax authorities.
Point dd, Clause 4, Article 5 of Circular No. 86/2024/TT-BTC provided that, after being granted a tax identification number (TIN), a foreign supplier would use such TIN to directly declare and pay tax, or provide it to a commercial bank, a payment intermediary service provider, or an authorized organization for withholding and paying tax on its behalf. However, Circular No. 86/2024/TT-BTC did not provide any exemption from tax registration procedures, where all revenue generated in Vietnam had already been subject to tax withholding and tax payment on behalf of the foreign supplier by an organization in Vietnam.
