Accounting compliance for foreign companies in Vietnam — the 2026 guide

If you operate a foreign-direct-investment (FDI) subsidiary in Vietnam — whether it's a 100% foreign-owned LLC, a joint venture, or a representative office — your accounting compliance load is heavier than a domestic Vietnamese SME's. You inherit every Vietnamese requirement, plus transfer pricing, plus FX handling, plus reporting to a parent in a different accounting standard.

We've helped 30+ FDI subsidiaries (Japan, Korea, Singapore, US, UK) navigate this in the past two years. This guide distills what their CFOs actually needed to know, in priority order, with the references their auditors quoted back at them.

1. The four foundational regulations

Vietnamese accounting is governed by four texts you will hear repeatedly:

1. The Accounting Law (Law 88/2015/QH13)— the constitutional document. Article 41 is the one your auditor will quote: 10-year retention for accounting records.
2. Circular 200/2014/TT-BTC (“TT 200”)— the Vietnamese Accounting Standards (VAS) for businesses, including the standard chart of accounts. Larger entities follow this; SMEs may follow TT 133. FDI subsidiaries default to TT 200.
3. Circular 78/2021/TT-BTC (“TT 78”)— mandatory electronic invoicing. Every taxable invoice issued by your subsidiary must flow through a GDT-certified provider (VNPT, Viettel, MISA-meInvoice, etc.).
4. Circular 32/2024/TT-BTC (“TT 32”)— electronic accounting books. Replaces the old paper-book regime: your general ledger, journals, and sub-ledgers can be (and increasingly must be) maintained electronically with tamper-evidence guarantees.

Everything else — transfer pricing, VAT, CIT, PIT, FX, audit — layers on top of these four.

2. Transfer pricing: Decree 132/2020 (FDI-specific)

This is the single rule that hits FDI subsidiaries hardest. Decree 132/2020/ND-CPrequires you to document and justify every transaction with a related party (your parent, sister subsidiaries, common-control entities), prove the pricing is arm's-length, and submit a related-party transaction declaration annually with your CIT return.

Forms involved:

• Form 01— information on related parties + nature of relationship
• Form 02 / 03 / 04— transaction-level disclosures, master file, local file (thresholds apply)

Penalties for non-disclosure can reach 20% of the underpaid CIT, plus interest. We cover Decree 132 in depth in a dedicated Vietnam Transfer Pricing for FDI guide.

3. E-invoicing under TT 78: bilingual is allowed (and recommended)

TT 78 mandates electronic invoicing for B2B (and B2C above ~VND 200,000), routed through a GDT-certified provider that assigns the invoice an authentication code. For FDI subsidiaries, two practical points:

• The invoice itself is in Vietnamese (required), but a bilingual presentation (Vietnamese on one side, your HQ language on the other) is explicitly allowed under Article 10 of TT 78. Your tax authority accepts it; your HQ finance team can read it. See our deep-dive on bilingual invoicing for FDI subsidiaries.
• The GDT-provider auth code is what makes the invoice valid — not your internal numbering. Reconciliation between your internal sequence and the GDT-issued code is where most FDI subsidiaries trip up. est-invoice handles this sync automatically.

4. FX rules: NHNN rates, transaction date, period-end revaluation

VAS requires three FX treatments for FDI:

1. Use the State Bank of Vietnam (NHNN) reference ratefor converting foreign-currency transactions to VND. Not your bank's rate. Not your parent's mid-market rate. NHNN's.
2. Record the rate on the transaction date, not period-end. Your accounting system must capture this and never silently swap it.
3. Revalue foreign-currency monetary balances at period-end; the gain/loss is recognized in the P&L (FX gain/loss accounts). Non-monetary items (inventory, fixed assets paid in FX) stay at the historical rate.

If your accounting software lets users overwrite the FX rate on a transaction without an audit trail, your annual audit will find it — and the auditor will require a comprehensive recomputation.

5. 10-year retention — Article 41 of the Accounting Law

Every accounting record, voucher, invoice, contract, and ledger entry must be retained for 10 years after the fiscal year of the transaction. For FDI subsidiaries, this compounds: your parent group may already require 7-year retention (US Sarbanes-Oxley or J-SOX), but Vietnam requires 10. Default to 10.

Practically, this means:

• You need three layers of backup minimum — production database, off-site (e.g. Cloudflare R2 or AWS S3 in a different region), and a cold archive.
• You need point-in-time restore capability — if an auditor asks for the books as of 31 December 2018, you must be able to produce them as they existed on that date.
• Hash-chain or RFC 3161 timestamp evidence makes auditor sign-off straightforward. est-invoice ships this by default.

6. Reporting: monthly, quarterly, annual

The cadence FDI subsidiaries actually live by:

• Monthly: VAT (Form 01/GTGT, due 20th of next month), withholding tax for foreign contractors, PIT for payroll (Form 05/PIT)
• Quarterly: VAT for small businesses, PIT estimate
• Annually:CIT finalization (Form 03/TNDN-DN, due 90 days after year-end), transfer pricing declarations (Decree 132 forms), audited financial statements (required for FDI — submit to MOF + tax authority + DPI)

7. Audit: who, when, how

FDI subsidiaries in Vietnam are required to be audited annually by a Vietnam-licensed audit firm (Big-4 are all licensed in-country: KPMG, PwC, Deloitte, EY). The audited statements are due 90 days after year-end, in Vietnamese, signed by the auditor.

Your auditor will spend ~60% of their time on three things:

1. Reconciling your books to the GDT-issued invoice trail (catches under-declared VAT)
2. Validating FX treatment on related-party transactions
3. Verifying the audit trail for any post-period-close adjustments

Choose accounting software that can produce these three datasets on demand without manual reconciliation. The Big-4 partners we work with explicitly favor systems with hash-chain immutability for this reason.

8. The CFO checklist for picking accounting software

For an FDI subsidiary, evaluate any candidate accounting tool against this seven-item checklist:

1. VAS-native chart of accountsmatching TT 200 (not a generic international CoA mapped to VAS — that breaks under audit)
2. GDT-certified e-invoice integration with VNPT or Viettel (the two largest providers)
3. NHNN FX rate auto-fetch with audit log of every rate used
4. Bilingual invoice / contract templates for HQ + tax authority consumption
5. Decree 132 related-party transaction extraction from AP/AR data
6. 10-year retention with hash-chain / RFC 3161 evidence, restorable to a date
7. English-language support and documentation— not a translated PDF, real support staff who can debug your accountant's issue

est-invoice ships all seven by default. If you're evaluating options, our team can run a no-pressure compliance walkthrough in English, Japanese, Korean, or Chinese — book a slot at /foreign-companies-vietnam.

Wrap-up

Vietnam's accounting framework rewards software that takes compliance seriously. The hardest parts — transfer pricing extraction, GDT invoice sync, NHNN FX, 10-year retention — are all solvable once, by the software, instead of every month by your accounting team. That's the lever we built est-invoice around.

For nationality-specific deep dives, see our country guides for Japanese companies in Vietnam, Korean companies in Vietnam, Chinese / Taiwanese companies in Vietnam, and Thai companies in Vietnam.