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Accounting | Statutory bookkeeping

A Vietnam entity must maintain Vietnamese statutory books even when its parent company reports under IFRS or another group standard.

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Overview

Statutory books, even under a parent IFRS regime

A Vietnam entity must maintain Vietnamese statutory books even when its parent company reports under IFRS or another group standard. For financial years beginning on or after January 1, 2026, Circular 99/2025/TT-BTC replaces Circular 200 for the enterprise accounting regime and applies to foreign-invested enterprises.

AreaForeign-invested company requirement
Accounting frameworkVietnamese Accounting Standards and the applicable enterprise accounting regime
Accounting booksGeneral ledger, subsidiary ledgers, journal entries, supporting documents, asset registers, inventory records, payroll, tax, and capital records
Language and currencyVietnamese statutory records (bilingual or group records may be maintained additionally); VND is the standard presentation currency
Financial statementsStatement of Financial Position, Statement of Profit or Loss, Statement of Cash Flows, and Notes
Accounting unitAppoint or outsource a qualified chief accountant or accounting-in-charge function
AuditForeign-invested enterprises generally require an annual statutory audit
Group reportingIFRS or parent-company reporting can be prepared in parallel, but it does not replace Vietnamese statutory books
Calendar

Mandatory reporting calendar

Filing or reportTypical timing
VAT and other tax returnsMonthly or quarterly, depending on the company's filing status
Payroll and PITMonthly or quarterly withholding filings, plus annual finalization
Foreign-contractor taxWhen payments to foreign suppliers trigger the applicable withholding rules
Social insuranceMonthly registration and contribution filings where applicable
Annual financial statementsGenerally within 90 days after fiscal year-end
Statutory audit reportComplete before the annual financial statements are submitted where audit is mandatory
Corporate income-tax finalizationAnnual finalization, typically coordinated with audited accounts
Investment and operational reportsPeriodic reports required under the investment framework or project approval

For a calendar-year company, the 90-day annual-financial-statement deadline usually falls around March 31 of the following year.

Before the first transaction

Accounting setup before launch

  1. Accounting policies and fiscal year.
  2. Chart of accounts mapped to the business model.
  3. VND and foreign-currency accounting treatment.
  4. Bank, DICA, and operating-account reconciliation procedures.
  5. E-invoice and sales-to-ledger integration.
  6. Inventory, fixed-asset, and expense-approval controls.
  7. Payroll, PIT, and social-insurance processes.
  8. Related-party and transfer-pricing documentation.
  9. Monthly closing and management-reporting timetable.
  10. Annual audit and tax-finalization timetable.
  11. Data retention, backup, and access controls.
  12. A bridge from VAS statutory books to the parent's IFRS or group reporting package.
Two ledgers

VAS and IFRS

An FDI company may need two reporting layers: Vietnam statutory reporting, prepared under Vietnamese requirements for tax, audit, regulators, banks, and local stakeholders; and group reporting, prepared under IFRS, US GAAP, or the parent's internal accounting policies.

The group ledger should not overwrite the statutory ledger. A controlled reconciliation should explain differences in revenue recognition, leases, depreciation, provisions, foreign-exchange treatment, deferred tax, and consolidation adjustments. Current guidance describes IFRS as an optional or parallel reporting route for many FDI enterprises, while VAS-based statutory reporting remains required.

Attention areas

Foreign-investor watchouts

  • Capital contributions recorded against DICA bank evidence.
  • Intercompany management fees, royalties, loans, and recharges.
  • Transfer-pricing documentation and related-party disclosures.
  • Withholding tax on payments to foreign affiliates, and e-invoice timing and VAT reconciliation.
  • Imported equipment, customs value, and fixed-asset capitalization.
  • Foreign-currency balances and unrealized FX gains or losses.
  • Profit distributions and the accounts supporting lawful remittance.
  • Accounting consequences of a capital increase, reduction, business suspension, or address change.

Statutory books first

An FDI company may report to its parent under IFRS, but it must maintain Vietnam-compliant accounting records, e-invoices, tax books, and audited financial statements for local statutory purposes.

For a 2026 setup, confirm that the accounting system, chart of accounts, financial-statement templates, internal policies, and audit engagement are configured for Circular 99 — not simply carried forward from the prior Circular 200 environment.

This article is for general information only and does not constitute legal advice. For further information, please contact Inventive Legal at suki.le@inventivelegal.com | +84 (77) 8727793 | inventivelegal.com

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