This is the technical reference companion to our Circular 99 overview (Part 1). Circular 99/2025/TT-BTC introduces 25+ account-level changes from Circular 200/2014, effective for fiscal years beginning January 1, 2026. The three changes that affect most FDI enterprises: autonomous chart of accounts customization, IFRS-aligned revenue recognition, and new dedicated accounts for biological assets and dividends payable.
Use the comparisons below to map your ERP migration and update internal accounting policies.
Chart of Accounts & Inventory
These changes affect how you structure your accounting system and value inventory.
| Area | Circular 200 | Circular 99 |
|---|---|---|
| Chart of Accounts | Used a fixed account system. Changing Level 1 or Level 2 accounts required written MoF approval. | You can now independently customize from Level 2 onwards. The circular specifies 71 mandatory Level 1 accounts. You must issue an Internal Accounting Policy documenting changes. Example: You can detail Cash (TK 111) as ‘111.VND’ and ‘111.USD’, or ‘1111’ and ‘1112’. |
| Inventory Valuation | Three methods: specific identification, weighted average, and FIFO. | Adds Standard Cost as a fourth method. Materials reserved beyond 12 months must be presented as long-term assets, not inventory. Account 611 (Purchases) is abolished. Example: Your manufacturing team can use Standard Costing for faster cost estimation, adjusting variances to COGS. |
Asset Accounting
New accounts and valuation options change how you record fixed assets, biological assets, and investment property.
| Area | Circular 200 | Circular 99 |
|---|---|---|
| Trading Securities (TK 121) | Cost included purchase price plus brokerage fees, transaction charges, and taxes. | Cost now equals only the Fair Value paid. Purchase costs (brokerage, charges) must be immediately expensed to Financial Expense (TK 635). |
| Held-to-Maturity (TK 128) | Tracked investments held to maturity, including time deposits, bonds, and loans. | Now requires an Impairment Provision (TK 229) when evidence suggests the investment may not be fully recoverable. Example: If a corporate bond shows signs that interest recovery is doubtful, you must set up a provision using TK 229. |
| PPE & Investment Property | Required Historical Cost model almost exclusively. Depreciation tracked through TK 214. | Introduces the Fair Value Model option for PPE and IP, aligning with IFRS. Going concern: You can elect to revalue property to Fair Value. Non-going concern: Depreciation is deducted directly from carrying value, bypassing TK 214. |
| Construction in Progress (TK 241) | Tracked procurement costs, construction expenditure, and major repairs. | Adds Account 2414 for upgrades, improvements, and crucially periodic repair and maintenance expenses. |
| Biological Assets | No dedicated account — biological assets (perennial crops, working livestock) were recorded as PPE (TK 211). | New Level 1 Account: TK 215 — Biological Assets, with impairment provision via TK 2295. Example: If you operate in agriculture, you must now separate fruit trees and breeding cattle (TK 215) from factory equipment (TK 211). |
| Investment Property (IP) | IP held for operating leases was depreciated, with expenses in production costs. | Same depreciation rule applies, even during rental suspension. Key change: IP held solely for capital appreciation is not depreciated but requires impairment testing, with losses booked to COGS (TK 632). |
| Investments in Other Entities | Cost basis for liquidated investments used moving weighted average. | BCC transition: Capital contributions to non-jointly controlled BCCs previously in TK 138 must transfer to TK 2281 upon Circular 99 adoption. |
| Investment in Subsidiaries (TK 221) | Reclassification to trading securities prohibited unless control was lost. | Same rule applies. Revaluation differences from contributing non-monetary assets to a subsidiary are recorded in Other Income (TK 711) or Other Expense (TK 811). |
| BCC Accounting | Non-legal entity BCC investments were generally not tracked in TK 228. | Clarifies treatment based on economic substance. Example: If one party handles accounting/taxation, the transaction is treated as a borrowing (for that party) or lending (for the other). |
| Impairment Provisions (TK 229) | Four Level 2 accounts: trading securities, investment impairment, doubtful debts, and inventory devaluation. | New TK 2295 — Biological Asset Impairment Provision. Doubtful debt provisions (TK 2293) and inventory devaluation (TK 2294) now require documented evidence confirming value decline. |
| Deferred Allocation Costs (TK 242) | Called “Prepaid Expenses.” Presented as short-term on the Statement of Financial Position. | Renamed “Deferred Allocation Costs.” Equitization goodwill must be allocated over max 3 years to G&A Expense (TK 642). |
Liabilities & Equity
Changes to how you classify dividends, preference shares, and owner’s equity.
| Area | Circular 200 | Circular 99 |
|---|---|---|
| Dividends Payable | Recorded within TK 338 (Other Payables). | New Level 1 Account: TK 332 — Dividends and Profit Payable. Upon transition, transfer the dividend balance from TK 338 to TK 332. |
| Taxes & Government Payables (TK 333) | Tracked direct and indirect taxes owed. | Adds Global Minimum Tax guidance: new TK 82112 for Supplementary CIT Expense under GloBE rules. Also adds TK 1383 for Special Consumption Tax on imports. |
| Borrowing & Lease Liabilities | Classified as short-term or long-term based on 12-month threshold. | Four specific conditions now define short-term classification, including liabilities held primarily for trading. Working capital payables remain current even if settlement exceeds 12 months. |
| Provisions Payable (TK 352) | Provisions had to meet VAS criteria. | Now allows pre-accrual for repair, maintenance, and asset restoration costs at the end of PPE lease contracts (per VAS 18). |
| S&T Development Fund (TK 356) | Tracked fund balance from post-tax profit for science and technology activities. | Same structure. When the Fund buys PPE, you must simultaneously increase PPE cost and TK 3562. |
| Owners’ Equity (TK 411) | TK 4112 was called “Share Premium.” Preferred stock was a liability only if mandatory repurchase applied. | TK 4112 renamed to “Capital Surplus.” Preferred share liability classification expanded to three triggers: (i) mandatory repurchase, (ii) mandatory fixed dividends regardless of profitability, OR (iii) conversion rights determined by market price. |
| Own Shares (TK 419) | Called “Treasury Stock.” | Renamed “Own Shares Repurchased.” Adds guidance for using these shares for employee bonuses. |
| Undistributed Profit (TK 421) | Tracked post-tax results and profit distribution status. | Same principles. New: Common control merger differences transfer to TK 4118 and reverse to TK 421 over max 10 years. |
Revenue & Expenses
The most impactful changes for your financial reporting — especially if you have long-term contracts.
| Area | Circular 200 | Circular 99 |
|---|---|---|
| Revenue Recognition (TK 511) | Revenue recognized on invoice date or risk transfer. | Now based on transfer of control and Performance Obligations, aligned with IFRS 15’s five-step model. Example: For real estate or long-term service contracts, you must identify distinct performance obligations and recognize revenue as control transfers — potentially over time rather than at a single point. |
| Financial Revenue (TK 515) | Covered interest, dividends, and profit shares. | Expanded: now includes gains from disposing or recovering financial investments (TK 121, 221, 222, 228), after offsetting impairment provisions (TK 229). |
| Other Income (TK 711) | Income outside core operations, including PPE disposal gains. | Now also covers revaluation differences when contributing non-monetary assets as capital. Payables where the creditor cannot be identified are recorded as other income. |
| Selling & G&A Expenses (TK 641/642) | Presented by function on the Income Statement. | Must now be classified by nature for greater transparency. Account 611 (Purchases) abolished, phasing out the Periodic Inventory Method. |
Foreign Exchange & Transactions
| Area | Circular 200 | Circular 99 |
|---|---|---|
| FX Rate Differences (TK 413) | “Actual transaction rate” was undefined, complicating ERP systems. Year-end revaluation used the bank’s buying rate. | Now standardized: the actual rate is the average transfer buying/selling rate of your most-used bank. You can apply an Approximation Rate (max ±1% deviation) during the period. Year-end revaluation uses the average transfer rate. |
Conclusion
The three most critical changes requiring your immediate attention: (1) draft your Internal Accounting Policy Regulation documenting any COA customizations, (2) adopt IFRS-aligned revenue recognition based on performance obligations and control transfer, and (3) implement new accounts (TK 215 Biological Assets, TK 332 Dividends Payable) and valuation methods (Fair Value Model for PPE/IP, Standard Cost for inventory).
For a complete overview of Vietnam’s accounting framework and all FDI compliance obligations, see our Accounting & Reporting Compliance guide →. To understand how these changes affect your VAS-IFRS dual reporting, statutory audit process, and chief accountant responsibilities, review the linked guides.
ICLV’s accounting and tax advisory team can help your business navigate the Circular 99 transition — from COA mapping to ERP reconfiguration. Contact us →
Legal Disclaimer
This article provides general information about Circular 99/2025/TT-BTC for referential purposes only. It should not be considered legal, tax, or accounting advice.
Regulations cited are subject to amendments and implementing guidance. Verify current regulatory status and consult licensed accounting professionals regarding your specific circumstances.
Indochina Link Vietnam accepts no liability for actions taken or losses incurred based on information in this article without independent professional verification.
