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The introduction of Decree No. 310/2025/ND-CP by the Vietnamese government marks a significant overhaul of the administrative penalties for tax and invoice violations, effective from January 16, 2025.

On December 2, 2025, the Government of Vietnam promulgated Decree No. 310/2025/ND-CP (“Decree 310”), which amends and supplements several provisions of Decree No. 125/2020/ND-CP on governing administrative penalties for tax and invoice violations. Effective from January 16, 2025, the new decree strengthens the legal framework for tax enforcement, clarifies sanctioning principles, introduces new compliance tools, and expands definitions of taxable administrative violations.

This article explains the key amendments under Decree 310, assesses their implications for businesses operating in Vietnam, and outlines the current tax enforcement landscape that enterprises must navigate in the coming year.

Expanded scope of administrative tax violations

A foundational change under Decree 310 is the expansion and clarification of the scope of administrative tax violations. The amended definition covers acts by organizations or individuals that breach tax administration laws, tax laws, or other revenue laws managed by tax authorities, but do not constitute criminal offenses. These acts include violations related to:

• Land use fees;
• Land and water surface rental fees;
• Fees for the granting of mineral exploitation rights;
• Fees for the granting of water resource exploitation rights;
• Remaining after-tax profits after the allocation to funds of enterprises wholly owned by the State;
• Dividends and distributed profits attributable to the State’s invested capital in joint-stock companies and limited liability companies with two or more members; and
• Other revenues in accordance with the laws on the management and investment of State capital in enterprises.

This broader scope aims to consolidate the types of state budget revenues subject to tax compliance and bring a wider array of revenue streams under administrative penalty provisions, reinforcing the tax authority’s oversight role.

Broader force majeure exemptions

Decree 310 also introduces explicit force majeure provisions for the first time in the context of tax and invoice penalties. Cases such as natural disasters, epidemics, fires, wars, strikes, riots, and other unforeseen events may now be considered for exemption from penalties if taxpayers show that they could not comply despite taking all possible preventive measures.

This change aligns administrative penalty practice with force majeure principles found in other areas of Vietnamese law and modern regulatory frameworks.

New sanctioned subjects and third-party liability

Traditionally, tax administration penalties focused directly on the taxpayer responsible for the tax declaration and payment. Under Decree 310, this is expanded to include third parties acting on behalf of taxpayers:

• Authorized agents who perform tax obligations on behalf of a taxpayer will be held directly responsible for violations committed in the course of that authority.
• Organizations or individuals legally obligated to register, declare, or pay tax on behalf of others are subject to sanctions if they commit violations.

This shift recognizes the practical realities of outsourcing tax compliance and places a greater onus on appointed representatives to observe proper tax and invoicing practices.

Notably, Decree 310 also clarifies the entities subject to administrative penalties in connection with the implementation of the Global Minimum Tax under the global anti–base erosion (GloBE) rules. These include:

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• Constituent entities that are required to register for tax, file tax returns, and pay supplementary corporate income tax; and
• Constituent entities designated by the Group to submit notifications identifying the constituent entity responsible for tax declaration and the list of constituent entities subject to Resolution No. 107/2023/QH15.

Where these entities commit administrative violations as prescribed in the Decree, they shall be subject to penalties in accordance with its provisions.

Revised penalties for invoice and documentation violations

Decree 310 introduces tiered, detailed penalty structures for invoice-related violations that were previously less granular.

Under the new regime, penalties for issuing invoices at the incorrect time or failing to issue an invoice will be determined based on the number of invoices involved and whether they relate to sales or internal uses such as promotions, gifts, or employee remuneration. Fines vary from warnings and small penalties for minor violations to a lump sum of up to VND 80 million (US$3,000), based on the nature and extent of the breach.

Decree 310 also amends penalties for destroying invoices beyond prescribed time limits, failing to destroy invoices as required, and violations related to the provision of e-invoice services and systems, further tightening compliance expectations around invoice management.

Procedural changes: single penalty rule and enforcement authorities

Another significant amendment under Decree 310 concerns how repeated violations of the same type are treated administratively.

Rather than penalizing each individual act separately, the decree introduces a principle of a single penalty for behaviors such as issuing invoices at the incorrect time or failing to issue invoices, where multiple violations of the same nature may occur within the statute of limitations. The fine applied will reflect the number of invoices involved rather than each discrete act.

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This change reduces the administrative burden of multi-count penalties and introduces a degree of predictability for businesses in managing compliance exposures.

The decree also strengthens the authority of tax officials and hierarchical enforcement powers. Tax officers on duty, heads of grassroots tax agencies, and directors of provincial tax offices are granted explicit powers to impose warnings and monetary fines, up to specified limits, for defined categories of violations.

Implications for compliance and internal controls

For businesses operating in Vietnam, the amendments under Decree 310 strengthen the need for robust tax and invoice compliance systems. Key implications include:

• Enhanced internal review mechanisms to ensure that all invoicing and tax declaration activities are timely, accurate, and aligned with legal requirements.
• Contractual safeguards with third-party tax agents, reflecting the new liability framework.
• Documentation and record-keeping, particularly where exemptions may be claimed due to force majeure events or other mitigating circumstances.
• Revised compliance thresholds, including tiered fine structures for invoice-related violations, raising the stakes for systematic errors.

Companies should consider updating internal compliance manuals, training staff on new penalty thresholds and enforcement procedures, and investing in technology solutions for automated invoice reporting and tax filings to avoid amplified penalties.

The evolving tax enforcement landscape in Vietnam

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Decree 310 is introduced as Vietnam’s tax administration increasingly emphasizes digitalization, transparency, and alignment with international standards. Mandatory e-invoicing systems, electronic tax filing, and improved data-sharing capabilities are all strengthening compliance efforts, raising the risk of penalties where controls are weak or outdated.

Vietnam’s tax authorities have also pursued broader reforms in tax dispute resolution, competition law, and cross-border information exchange, signaling a comprehensive approach to modernizing the business tax framework.

While this progress offers long-term benefits in terms of clarity and predictability, the short-term impact is an increased administrative burden on businesses to align operations with evolving regulatory standards.

Outlook and next steps for businesses

As Decree 310 takes effect from January 16, 2026, companies should prioritize compliance readiness. Transitional provisions allow the continued application of previous decree rules to violations that occurred before the effective date, but to violations discovered after, the new rules will apply. Businesses with outstanding tax and invoice issues should assess whether legacy practices need remediation under the updated framework.

For international investors and domestic enterprises alike, understanding these changes is essential to maintain tax compliance, manage risk, and support sustainable growth within Vietnam’s increasingly digitalized regulatory landscape.

See also: Vietnam’s Tax and Accounting Updates for Businesses in 2026

Entertainment Companion: Extending the Experience Beyond Simple Viewing

SW Yong, President and Head of the Visual Display (VD) Business at Samsung Electronics, and Sukhmani Mohta, Chief Marketing and Partnerships Officer, VD Business at Samsung Electronics America took the stage to describe how Samsung’s displays are combining hardware excellence and visual intelligence to provide a true entertainment companion. Drawing from twenty years of leading the TV industry, Samsung has built a full AI TV lineup that provides an entirely new way for users to interact with their TV.

The center of the display lineup is the 130-inch Micro RGB, which represents a monumental leap in scale and picture quality. The 130-inch Micro RGB marks a new era of color, featuring the widest and most detailed spectrum ever seen in Samsung TVs while its Timeless Frame design minimizes distractions and allows the picture to take center stage with understated elegance. A micro-sized RGB light source drives the unprecedented picture quality, with each microscopic red, green, and blue diode shining independently to produce color in its purest, most natural form. Micro RGBAI Engine Pro enables precise control of RGB colors and creates overwhelmingly vivid picture quality in every scene.

Elevating this next-level viewing experience, Vision AI Companion (VAC)¹ uses AI technology to work alongside users as a full entertainment companion to enhance viewing, dining, and mood, anywhere in the home. With it, users can receive guidance on what to watch, what to eat, and what music to listen to, enhancing the overall TV experience in a way that extends far beyond simple viewing.

Samsung also offers intuitive modes to personalize the viewing experience. For soccer fans, AI Soccer Mode Pro delivers a more exciting gameday experience through AI-driven picture and sound tuning to stadium-level quality. AI Sound Controller Pro lets you raise or lower the volume of the crowd, commentary, or background music, providing a personalized listening experience for TV shows and movies. Users can simply make verbal requests, and any TV equipped with VAC – which includes Micro LED, Micro RGB, OLED, Neo QLED, Mini LED and UHD TV – contextually carries out those requests.

Across different types of programming, VAC also boosts the overall lifestyle experience. It allows users to find recipes for meals they see on TV by simply asking and uses the most up-to-date information to make recommendations that align with health and fitness goals. VAC offers multi-device functionality, as well, sending recommended recipes directly to other devices like the newly-unveiled The Movingstyle, designed to move easily throughout the home and kitchen appliances, for a multi-device experience achieved through complete ecosystem integration.

Samsung has led the global soundbar market for 11 consecutive years. This year, it is introducing two new WiFi speakers, the Music Studio 5 and 7, to further expand its integrated ecosystem. These models support a wider range of sound system combinations, enhance audiovisual quality, and improve the aesthetics of any space. Each model shares a timeless, dot design concept by renowned designer Erwan Bouroullec, inspired by a universal symbol in music and art and grounded in Samsung’s signature design language.

Samsung also unveiled a host of new products that blend beautifully with users’ homes and aesthetics.  The new, ultra-thin OLED S95H features a refined bezel that gives it art gallery elegance, and Samsung’s new portable projector, The Freestyle+, is powered by VAC and allows users to view content on walls and ceilings, as well as uneven surfaces like corners and curtains.

The 2026 TV lineup² supports HDR10+ ADVANCED, delivering enhanced brightness, genre-based optimization, intelligent motion smoothing, advanced local tone mapping, and improved gaming experience.

As HDR10+ adoption grows among major OTT providers, Samsung will be the first to launch HDR10+ ADVANCED in its 2026 TV lineup. Samsung also features Eclipsa Audio, the company’s new spatial sound system, introduced across all 2026 TVs.

Samsung also unveiled its most advanced Odyssey gaming monitor lineup yet, introducing five new models that push the boundaries of resolution, refresh rate, and immersive visual performance. Led by Samsung’s first 6K 3D Odyssey G9, the 2026 lineup debuts world-first display technologies for gamers and creators, including the next-generation Odyssey G6 and three new Odyssey G8 models.

At the center of all these display innovations is the most powerful Tizen OS yet. Users can now enjoy seven years of Tizen OS upgrades, ensuring that TVs continue to evolve long after they have entered the home.

Home Companion: Connected Smart Appliances That Guide You Through Your Day

Cheolgi Kim, Executive Vice President and Head of Digital Appliances (DA) Division at Samsung Electronics, and Elizabeth Anderson, Head of Integrated Marketing, DA at Samsung Electronics America (SEA) outlined Samsung’s vision to evolve from providing home appliances to true home companions that work to eliminate the stress of daily chores. Cheolgi Kim also announced that as of December 2025, SmartThings now serves more than 430 million users, empowering Samsung with a significant scale and depth of insight that sets it apart from other brands.

This insight comes to life with the Family Hub. The AI-enabled refrigerator is the centerpiece of the home and now, with an upgrade to AI Vision built with Google Gemini³, it redefines living for an AI future. With this update, AI Vision unlocks existing limitations in recognizing food items, seamlessly tracking what is placed into and taken out of the refrigerator, making meal planning and food management simpler than ever⁴. The Family Hub has won 10 CES Innovation Awards so far, and Samsung’s AI-enabled fridges have received the award for the past three years.

Through a gamified feature called “What’s for Today?”⁵, select refrigerators provide recipe recommendations based on what is in the refrigerator or also random recommendations, reducing the stress caused by choosing what to cook. When selected, recipes show up through SmartThings Food, where users receive a step-by-step guide to help them get started instantly. The selected recipe can also be sent to connected cooking appliances to begin the process seamlessly. Video to Recipe adds even more simplicity, providing users with recommended cooking videos and converting those videos into easy-to-follow steps, allowing users to follow along while they cook without pausing the video or backtracking.

Samsung also unveiled FoodNote, a new, weekly report that recaps users’ food intake patterns, from most-used ingredients and recipe recommendations, and which items it’s time to restock. Additionally, Now Brief⁶ includes more widgets on the Family Hub screen and with Voice ID⁷, can distinguish between family members and display content relevant to each individual. Ultimately, these features come together to provide various helpful insights and information throughout the week.

In the laundry room, the Bespoke AI Laundry Combo removes the need to transfer loads of laundry, solving a major pain point for households. This year’s model comes with enhanced features, like a faster super speed cycle and enhanced drying performance. Moreover, Samsung’s new Bespoke AI AirDresser is here to solve another common problem with your clothes. It features Auto Wrinkle Care, which blasts strong air and steam jets to smooth out shirts. All users have to do is hang their shirt and wait, reducing the burden in busy mornings.

Around the house, the Bespoke AI Jet Bot Steam Ultra, powered by a Qualcomm Dragonwing™ processor, features an Active Stereo 3D Sensor to recognize liquids⁸ like coffee, juice, or even transparent liquids like water. While its camera helps with navigation, it also allows the robot vacuum to serve as a monitoring device for when users are away from home, notifying them about their pets and whether there is any suspicious activity⁹. Plus, with a smarter Bixby¹⁰, users can speak conversationally to their robot vacuum to carry out tasks with ease. For the deep level of connectivity and integration that forms the backbone of a holistic, AI-powered experience, Samsung’s Bespoke AI appliances have received a CES Innovation Award.

Additional benefits include a first-of-its-kind partnership with Hartford Steam Boiler (HSB) to help unlock real, meaningful savings to the smart home experience. HSB President and CEO Greg M. Barats joined the presentation to discuss the partnership, explaining the potential benefits of having smart appliances connected to SmartThings to reduce insurance premiums. This is the best of the AI era – increased protections and reduced costs for users. After a successful pilot run in the U.S. in 2025, the collaboration is expanding to more states across the U.S., as well as to leading home insurance carriers in other global regions.

Care Companion: Shifting From Reactive to Proactive Care

Finally, Praveen Raja, Vice President and Head of Digital Health at Samsung Research America (SRA), introduced Samsung’s long-term vision for intelligent care enabled by Samsung’s integrated device ecosystem, redefining care as a reactive need to a proactive opportunity. With AI, phones, appliances, wearables, and other connected devices will help users prevent potential health concerns before they occur.

For example, Samsung aims to provide personalized health coaching, offering effective exercise and sleep coaching to help decrease risk for major chronic diseases and also suggesting appropriate recipes based on ingredients available in connected refrigerators. Additionally, if any abnormal signs or patterns are detected, it will alert users while allowing their health metrics to be shared with providers via the Xealth platform and to facilitating virtual professional consultations.

Recognizing the importance of preventative health, Samsung is also expanding its capabilities in dementia detection through research partnerships, with wearable devices registering subtle changes to mobility, speech and engagement that can be indicative of long-term cognitive changes.

Samsung Knox and Knox Matrix serve as the foundation of this hyper-personalized ecosystem, safeguarding user data at every turn. As AI is constantly evolving, so are Knox and Knox Matrix. To maintain security despite constant changes, Samsung’s security systems are consistently identifying AI risks by advancing to protect data in AI training processes and approving models through red team analysis.

The Samsung Exhibition Zone at CES is available to the public Jan. 4-7. For more information, visit the Samsung Newsroom.

¹ Feature available in certain regions and models. Availability and supported features may vary by region and watching conditions. Voice commands recognize English, French, Spanish, Portuguese, German, Italian, and Korean, but not all accents, dialects, and expressions are recognized. This feature provides AI-created content, with accuracy not guaranteed, so results should be confirmed. Requires a specific Bluetooth remote (TM2660H/TM2661H) (sold separately on some models). In-box remote for some models (M70H/U800H) does not support voice recognition. Requires either a Mobile Quick Remote or separately purchased Bluetooth remote. Feature accessible with the AI button or the Home button (via long press) on remote controls without an AI button.

² HDR10+ ADVANCED will be available on the following models: QN990H, R95H, S95H, S90H, R90H, S85H, LS03HW, LS03H, and QN80H.

³ Google Gemini is provided by Google LLC. Service availability, supported functions, and accuracy may vary by country, language, device model, and OS/One UI version. Users must be 18 or older. Some functions may require additional app settings, and features or results may vary by subscription.

⁴ AI Vision refers to the refrigerator’s internal camera and AI-based processing that helps recognize food items. A Wi-Fi connection and a Samsung account are required. If a food item is not recognizable, it may be listed as an unknown item. AI Vision cannot identify or list any food items in the freezer. Recognition uses AI models that may be updated periodically to help improve performance. The user may need to manually check and adjust the list to ensure its accuracy.

A red light turns on when the camera is operating. The user’s appearance may be captured, but areas other than the food item are automatically blurred.

⁵ A Wi-Fi connection and a Samsung account are required

⁶ A Wi-Fi connection and a Samsung, Google, or Microsoft account may be required. You must use the same log-in account on each of the devices. Availability of certain apps may vary by country, region, service provider, network environment, or device, and may change without notice.

⁷ Each user must register for a Samsung Account on screen appliances in advance. Up to six accounts can be registered on a single device. To use Voice ID, users must have agreed to the Bixby terms and conditions. Voice ID registration is available on select appliances, TVs and mobiles, and only one voice can be registered per account.

⁸ A liquid spill is defined as a colored or transparent liquid, such as water or juice, having a size of 7cm x 7cm (15 ml in volume) or larger. Identification may be affected by the size of the liquid or the environmental conditions of the floor, such as the floor pattern, color of the floor, direct or reflected light, or shape of the liquid. Excessive amount of liquid on the floor may cause secondary contamination.

⁹ Must download the SmartThings app available on Android and iOS devices. A Wi-Fi connection and a Samsung account are required. Only cats and dogs can be recognized. The recognition capabilities may be limited by the posture or position of a pet. The ability to recognize your pet may vary depending on the type of animal and the living environment. It only recognizes a pet presence based on generic visual indicators, and cannot identify individual pets. Each appliance needs to be set to be optimized for pets by the SmartThings App.

¹⁰ Bixby is Samsung’s brand of Internet of Things (IoT) voice assistant. Bixby service availability may vary depending on the country. Bixby recognizes selected languages and certain accents/dialects, including Korean, English (US/GB/IN), Spanish (MX/ES), German, French, Italian, and Portuguese (BR). The user interface may change and differ by device. The availability of Bixby features and content providers may vary depending on the country/carrier/language/device model/OS version. A Samsung account log-in and data network connection (Wi-Fi or data network) are required.