Vietnam

Taxing e-commerce activities

In September 2021, the Ministry of Finance (MoF) officially issued Circular 80/2021/TT-BTC (Circular 80) providing detailed guidance on the Law on Tax Administration on various matters, which also have a chapter focus on the tax filing mechanism for foreign companies doing e-commerce, digital business, and other business in Vietnam without a permanent establishment (PE). The General Department of Taxation (GDT) officially launched the portal for direct tax registration, declaration, and payments by e-commerce companies in Vietnam on 21 March 2022. The GDT published the names of 161 foreign companies registering up to June 2025.

According to the new Law on Corporate Income Tax (CIT), which will take effect from 1 October 2025, foreign companies using e-commerce and digital platforms to supply goods/services in Vietnam are now formally included within the scope of the new CIT Law. In addition, these platforms are now officially included in the definition of PEs, potentially impacting double taxation agreement (DTA) exemption claims.