An FDI accounting system has to satisfy Vietnamese accounting standards, tax rules and foreign exchange controls at the same time. The first decision is the accounting regime, and the rest follows from it.
The gap between Vietnamese Accounting Standards (VAS) and IFRS creates costly traps when a company designs its system without local rules in mind. Circular 99/2025/TT-BTC sets the bookkeeping basis, while expense deductibility follows the tax laws and e-invoice rules. A compliant system built from the licensing stage makes it easier to support deductions, pass the statutory audit and document cross-border profit remittances. It is one part of the wider FDI accounting and reporting framework.
1. Legal Framework and Accounting Regime Selection for FDI Entities
The corporate accounting regime operates under the Law on Accounting No. 88/2015/QH13 (as amended by Law 56/2024/QH15), Decree No. 174/2016/ND-CP, and Ministry of Finance circulars on enterprise accounting.
A new FDI entity chooses its accounting regime before the first accounting period starts:
- Circular 99/2025/TT-BTC (Enterprise Accounting Regime): Effective from January 1, 2026, for financial years beginning on or after that date, replacing Circular 200/2014/TT-BTC. Circular 99 applies to enterprises in all sectors (credit institutions follow State Bank of Vietnam guidance), while accounting for state-owned enterprise equitization still follows Circular 200. It provides a detailed chart of accounts and accounting controls, plus treatment for newer items such as Biological Assets (Account 215) and Global Minimum Tax top-up obligations (Account 82112). The selected regime must be applied consistently across the fiscal period.
- Circular 133/2016/TT-BTC (Simplified Accounting System for SMEs): Applicable to enterprises that meet the statutory criteria for small and medium-sized enterprises, with a condensed ledger and simplified financial reporting. Small and medium-sized enterprises may also elect Circular 99 instead.
Micro and small FDI entities can register under Circular 133, but most foreign-invested entities, particularly manufacturing plants, export processing entities and subsidiaries with related-party transactions, choose Circular 99. It avoids database reconfiguration costs as the business scales and simplifies the conversion worksheets needed for group IFRS consolidation. The comparison of regimes for VAS and IFRS reporting shows where the two diverge.
2. Accounting Organization and Chief Accountant Appointment Rules
An enterprise cannot leave its accounting leadership position vacant. Under Decree 174, a unit that cannot appoint a Chief Accountant immediately may assign a Person in Charge of Accounting (Người phụ trách kế toán) or retain a licensed accounting service to act as Chief Accountant. The Person in Charge of Accounting may serve for up to 12 months. After that, the enterprise must appoint a Chief Accountant who meets the Law on Accounting’s requirements or decide to hire a licensed chief-accountant service.
Right after incorporation, the legal representative designates the Person in Charge of Accounting or Chief Accountant and declares this person in the tax registration dossier where the taxpayer registers directly with the tax authority (item 17.2 of Form 01-ĐKT, Circular 90/2026/TT-BTC). Banks and e-invoice providers usually ask for the accounting contact when setting up foreign investment capital accounts (formerly DICA), digital signatures and e-invoicing. Qualifications, penalties and outsourcing are covered in the guide to the Chief Accountant in Vietnam.
3. Chart of Accounts Configuration and ERP Software Integration
A common technical problem for multinationals is the conflict between the group chart of accounts and the Vietnamese chart. Statutory accounting records must be kept in Vietnamese (or bilingual Vietnamese and English) using the default account numbering scheme prescribed by the Ministry of Finance:
- Class 1 and 2 Accounts (Assets): Manage cash funds, capital accounts, current operating accounts, accounts receivable, and inventory categories. Segregation between capital accounts and commercial operational accounts is mandatory.
- Class 3 and 4 Accounts (Liabilities and Equity): Account for vendor trade payables, short-term and medium-long-term foreign shareholder loans (requiring State Bank of Vietnam registration if tenor exceeds 1 year), and charter capital contributions specified on the IRC.
- Class 5, 6, 7, 8, and 9 Accounts (Revenues and Expenses): Record operating income, direct cost of sales, selling and administrative expenses, financial charges, and net profit determination across General Journals and General Ledgers.
Vouchers used for bookkeeping, ledgers and annual financial statements must be kept for at least 10 years, and other management records for 5 years (Law on Accounting).
Circular 99 lets you rename, renumber or restructure accounts to fit your ERP, as long as the financial statement lines do not change and you issue an internal accounting regulation (Article 11.2). A mapping matrix is the alternative when you keep the group chart. When deploying an ERP such as SAP, Oracle NetSuite or Microsoft Dynamics, set up the bidirectional mapping rules from the start so the system produces VAS-compliant General Ledgers and Trial Balances without distorting headquarters IFRS reporting. ICLV sets up the account mapping and keeps the books under Circular 99 through its bookkeeping service.
4. Daily Bookkeeping, E-Invoice Compliance, and Tax Deductibility Requirements
Business expenses backed by valid contracts and bank advices are still disallowed in a tax audit if the documentation standards are breached.
Under Decree 254/2026/ND-CP (replacing Decree 123/2020/ND-CP) and Circular 91/2026/TT-BTC (effective July 1, 2026), inbound purchase invoices must be valid e-invoices (coded or uncoded depending on the seller category), and the buyer legal name, tax code and address must match the ERC or IRC and the tax registration record (standard abbreviations such as “Co., Ltd” or “KCN” are accepted). Imported goods also need the customs clearance declaration. Check vendor invoices on the tax portal before booking, as a control against fraudulent or suspended invoices.
Purchase invoices must also be backed by non-cash payment vouchers, such as bank payment confirmations, except in the special cases the Government allows. Under the Law on Corporate Income Tax (Law 67/2025/QH15) and Law on Value-Added Tax (Law 48/2024/QH15 effective July 1, 2025), non-cash settlement applies to transactions of VND 5 million or more, both for CIT deductible expenses (Article 9.1.c Decree 320/2025/ND-CP) and for input VAT credits (Article 26 of Decree 181/2025/ND-CP). Cash settlements at or above these thresholds put both at risk.
Intercompany charges (management allocations, technical service fees, royalties, expatriate salary recharges) need formal contracts, timesheets, delivery logs and Foreign Contractor Tax (FCT) filings. They must also meet Article 16 of Decree 255/2026/ND-CP (arm’s-length basis, direct link to business operations, supporting documents and a consistent allocation method). Interest expense is capped at 30% of net business profit plus net interest expense plus depreciation under the same Decree, effective from the 2026 CIT period and replacing Decrees 132/2020/ND-CP and 20/2025/ND-CP.
5. Year-End Book Closing and Four Core Financial Statement Components
Year-end closing reviews expense accruals, inventory net realizable value provisions, bad debt allowances and fixed asset depreciation under current regulations, aligned with a physical inventory count on December 31.
Under Circular 99, the annual statutory financial statement package has four core components:
- Statement of Financial Position (Balance Sheet): Summarizes short-term and long-term assets, liabilities and total shareholder equity at year-end.
- Statement of Business Results (Income Statement, Form B02-DN): Details net sales, cost of goods sold, financial income and expenses, selling and general administrative expenses, and operating income before and after CIT.
- Statement of Cash Flows: Tracks cash inflows and outflows across operating, investing and financing activities.
- Notes to the Financial Statements: Disclose accounting policies, asset movement schedules, loan terms, related-party transactions and non-adjusting post-balance sheet events.
For foreign-invested subsidiaries, auditors and tax inspectors scrutinize the Notes most closely to test transfer pricing substance and arm’s-length compliance.
6. 90-Day Statutory Audit Process and Profit Repatriation Blocking Risks
All foreign-invested enterprises in Vietnam must have their annual financial statements audited under the Law on Independent Audit No. 67/2011/QH12 (as amended by Law 56/2024/QH15) and Government Decree No. 17/2012/ND-CP. The audit must be completed and the statements filed within 90 days of fiscal year-end (March 31 for calendar-year entities), with the competent state authorities (Law on Accounting). The statutory audit guide covers the steps. The main filings are:
- The supervising Tax Office via the eTax portal, with the annual CIT finalization dossier.
- The investment registration authority (Department of Finance or Industrial Zone Management Board), through the annual investment-activity report on the National Investment Information System by March 31 (Articles 94 and 96 of Decree 96/2026/ND-CP).
- The local statistics authority, which receives the same annual investment-activity report.
Late filing of financial statements is fined VND 5 million to VND 20 million depending on the delay (Article 12 of Decree 41/2018/ND-CP), and failing to conduct a mandatory audit VND 40 million to VND 50 million (Decree 228/2025/ND-CP). Under Article 27 of Decree 252/2026/ND-CP, a foreign investor may remit profit abroad after the financial year ends only when the enterprise has filed the audited financial statements and the CIT finalization return, has paid all taxes, other amounts, late-payment interest and administrative fines due, and has no tax debt at the time of transfer. The investor also cannot remit the profit of a year if the financial statements for that year still show an accumulated loss after loss carry-forward. Disciplined initial accounting setup is the best protection for foreign capital returns.
Need help opening the books under Circular 99? Contact ICLV’s accounting team.
