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Accordingly, the Official Dispatch requests tax authorities to promptly study, implement, disseminate and communicate the new provisions of the Circular to tax officials and taxpayers to facilitate its implementation.
While inheriting the previous framework, the Circular further emphasizes that:
- Tax compliance management and tax risk management must be conducted objectively, transparently, in accordance with law, and without discrimination among taxpayers;
- Data analysis must be based on objective, comprehensive, and regularly updated databases, with priority given to the application of big data, machine learning, and artificial intelligence (AI) to automate data collection, processing, analysis, assessment, and classification;
- Results of tax compliance assessment and classification and tax risk assessment and classification must be recorded, monitored, and traceable, serving as the basis for developing compliance improvement plans, targeted inspection and supervision plans, and appropriate tax administration measures.
Regarding technological tools, Circular No. 94/2026/TT-BTC introduces the tax compliance management and tax risk management application, an information technology system designed to support tax authorities in analyzing taxpayer compliance, assessing tax risks, and assisting decision-making.
More specifically, the Circular provides that this application is developed to:
- collect, standardize, process and analyze data; assess and classify tax compliance levels and tax risk levels;
- manage tax compliance dossiers and tax risk dossiers;
- provide warnings, recommend tax administration measures, and monitor, trace and collect feedback on implementation results to continuously improve tax administration effectiveness.
The Circular also clarifies that the analyses, assessments, warnings and recommendations generated by the application serve only as a basis to assist tax authorities and tax officials in considering and deciding appropriate tax administration measures, and do not replace the responsibilities of competent persons as prescribed by law.
Accordingly, Circular No. 94/2026/TT-BTC goes beyond merely requiring the application of information technology by establishing a digital tax compliance and risk management framework featuring dedicated system modules, risk registers, risk criteria, and assessment models.
To modernize tax administration, the Circular also introduces several new measures, including:
- expanding information sources for tax compliance and tax risk management to include data from state agencies, organizations, individuals, international data sources, social surveys, and other lawful sources;
- promoting the application of big data, machine learning, artificial intelligence (AI), and other advanced analytical technologies in compliance assessment, risk classification, forecasting, and early warning;
- establishing mechanisms to update and incorporate feedback on the implementation of tax administration measures, thereby continuously improving risk criteria, assessment models, and the effectiveness of tax compliance management.
