VI Does a Company With No Revenue Still Need to File Taxes in Vietnam? 2026 Guide
Updated: October 23, 2026
You have just established a company but have not yet secured any customers, issued any sales invoices, or even begun business operations. Many business owners assume that if their company has no revenue, they do not need to file tax returns or engage an accountant.
However, a company with no revenue may still be required to file tax returns and comply with accounting obligations under Vietnamese law. The absence of revenue does not automatically exempt a business from all tax filing requirements.
Several tax administration regulations have changed in 2026. This article explains which filing obligations may still apply, when exemptions are available, and what newly established businesses should review to avoid overlooking their responsibilities.
1. Does a company with no revenue still need to file tax returns?
Having no revenue does not automatically exempt a company from filing obligations. Under Clause 1, Article 12 of the Law on Tax Administration No. 108/2025/QH15, taxpayers are required to make accurate, truthful, and complete declarations for the relevant taxes, subject to applicable statutory exceptions. The Law took effect on July 1, 2026.
The short answer is: the company may still need to file tax returns, depending on the tax concerned and its operating status.
Business owners should distinguish between three situations:
- No revenue, but business operations are continuing: The company may be renting office space, purchasing equipment, incurring expenses, or preparing to launch. Such activities do not automatically exempt it from tax return filing.
- No business transactions have taken place: The company has not purchased or sold goods or services and has earned no revenue. Its filing obligations must nevertheless be assessed separately for each type of tax.
- Business operations have been lawfully suspended: The company may qualify for an exemption from filing tax returns during its registered suspension period, subject to the relevant conditions and exceptions.
Under Article 11 of Government Decree No. 252/2026/ND-CP, detailing certain provisions of and measures for implementing the Law on Tax Administration, exemptions from tax return filing apply only where the prescribed conditions are met. Consequently, having no revenue does not, by itself, justify not filing a tax return.
2. What tax obligations may apply to a company with no revenue?
The obligation to file a tax return, or eligibility for an exemption, must be assessed under Article 11 of Decree No. 252/2026/ND-CP. Companies should examine each tax separately in light of their actual operating status.
If your business is uncertain about its obligations, PhamConsult’s tax consulting services can help assess its filing position and the appropriate scope of support.
2.1. Value-added tax (VAT)
Companies should identify their VAT calculation method, filing frequency, and any applicable filing exemptions. Relevant guidance is provided in Circular No. 89/2026/TT-BTC.
For businesses required to file VAT returns, the absence of sales or output invoices does not, on its own, entitle them to skip a filing period.
Under Point b.1.2, Clause 1, Article 19 of Ministry of Finance Circular No. 89/2026/TT-BTC, detailing certain provisions of the Law on Tax Administration and Government Decree No. 252/2026/ND-CP, taxpayers that have newly commenced business operations may opt for quarterly VAT filing. Their filing frequency in subsequent years depends on revenue and other applicable conditions.
Under Clauses 2 and 3, Article 10 of Decree No. 252/2026/ND-CP, the general tax return filing deadlines are as follows:
| Filing frequency | General filing deadline |
| Monthly | No later than the 20th day of the following month |
| Quarterly | No later than the last day of the first month of the following quarter |
The actual deadline may also be affected by public holidays, special circumstances, or any applicable filing extensions.
Example: A newly established trading company has not generated any sales revenue but has rented an office and purchased computers. It should record and review its input documents and determine which VAT returns, if any, must be submitted under its applicable filing arrangements.
Under Clauses 1 and 3, Article 11 of Decree No. 252/2026/ND-CP, certain taxpayers engaged exclusively in activities not subject to VAT, or export processing enterprises engaged exclusively in export processing activities, may fall within specific tax return filing exemptions. The full eligibility conditions and exceptions must be reviewed before relying on such exemptions.
2.2. Corporate income tax (CIT)
A common misconception is that a company with zero revenue has no corporate income tax obligations to consider.
In practice, having no sales revenue does not necessarily mean the company has no taxable income, no corporate income tax payable, or no obligation to submit an annual CIT finalization return. These are separate questions.
The amount of CIT payable is determined based on taxable income and the applicable tax rate under Articles 6 and 7 of the Law on Corporate Income Tax No. 67/2025/QH15. Where a business has no taxable income, it may have no CIT payable, but it must still assess whether an annual tax finalization return is required. For taxpayers subject to finalization, Point a, Clause 5, Article 10 of Decree No. 252/2026/ND-CP sets the general deadline as the last day of the third month following the end of the relevant tax finalization period.
Under Clauses 1 and 2, Article 3 of the Law on Corporate Income Tax No. 67/2025/QH15, taxable income may include income from production and business activities as well as other income. A company with no sales revenue should therefore still check whether any other income has arisen when determining its CIT position. For a company with no revenue, interest earned on bank deposits is one example of income that may still need to be considered when assessing corporate income tax obligations.
2.3. Personal income tax (PIT)
A company’s PIT filing obligations depend on whether it pays income, withholds PIT, and meets other applicable conditions.
Under Clause 6, Article 11 of Decree No. 252/2026/ND-CP, organizations and individuals otherwise required to file PIT returns monthly or quarterly but with no PIT withheld during the period are generally not required to file for that period. Exceptions may apply, including certain year-end filing periods and cases involving division, separation, consolidation, merger, dissolution, bankruptcy, or cessation of business activities.
Under Clause 7, Article 11 of the same Decree, organizations and individuals that have not paid any employment or wage income are not required to submit a PIT finalization return in respect of such income.
Important: A company may have no business revenue while still paying salaries. In that case, employment-related PIT obligations may still arise.
2.4. Business license fee in 2026
Under Clause 7, Article 10 of National Assembly Resolution No. 198/2025/QH15 on special mechanisms and policies for private sector development, the collection and payment of the business license fee (lệ phí môn bài) were discontinued from January 1, 2026. Businesses may also refer to the Vietnamese Government Portal’s official explanation of the abolition of the business license fee from 2026.
According to Official Letter No. 645/CT-CS dated January 23, 2026, issued by the Tax Department, taxpayers are no longer required to submit business license fee declarations for 2026 and subsequent years.
However, outstanding business license fee liabilities arising in 2025 or earlier must still be addressed in accordance with applicable regulations.
3. Does a company with no revenue still need to maintain accounting records and prepare financial statements?
Even without sales revenue, a company may have transactions that must be recorded in its accounting books. The responsibility to organize accounting activities is governed by the Law on Accounting No. 88/2015/QH13. For further background, readers may consult PhamConsult’s English-language article, What Are the Details of the Latest Accounting Law 2026 and Its Guiding Documents?.
An important distinction is often overlooked: no revenue does not necessarily mean no accounting transactions.
Even during the pre-operating stage, a company may receive capital contributions, pay office rent, purchase assets or software, or enter into transactions with suppliers.
Under Clauses 1 and 5, Article 5 of the Law on Accounting No. 88/2015/QH13, accounting information must fully reflect economic and financial transactions and be recorded on a continuous basis as required by law. Accordingly, businesses should retain, review, and record supporting documents even if no revenue has yet been generated.
For example, a company established in August 2026 may have signed no customer contracts but already incurred expenses for office rent and equipment. Without properly retaining supporting documents from the outset, its accounting team may encounter difficulties reconciling cash, assets, and expenses at year-end.
Under Point a, Clause 2, Article 29 of the Law on Accounting No. 88/2015/QH13, accounting entities within the relevant scope must prepare financial statements at the end of the annual accounting period. Clause 3 of Article 29 also governs the submission deadline within its scope of application. Therefore, a company should determine its obligation to prepare and submit annual financial statements even where no revenue has arisen.
Establishing an accounting system early also helps a business monitor how its capital is used, classify expenses, and prepare reliable financial data once commercial operations begin.
4. What should newly established companies review to avoid missing tax obligations?
For a company with no revenue, maintaining a clear tax compliance checklist is particularly important during the early stages of business operations, when filing obligations may arise before the company generates its first sales.
Rather than asking only whether a tax return is required, businesses should maintain a regular compliance checklist. For a company with no revenue, this checklist should also identify who is responsible for preparing each tax return, reviewing supporting documents, and confirming successful submission to the tax authorities.
| Area to review | Key considerations |
| Operating status | Is the company active, not yet trading, or formally suspended? |
| VAT obligations | Which calculation method, filing frequency, and filing requirements apply? |
| PIT obligations | Have salaries been paid or PIT amounts withheld during the period? |
| CIT obligations | What expenses, other income, provisional payments, and annual finalization requirements apply? |
| Accounting records | Are vouchers, books, bank records, and asset information properly maintained? |
| Annual reporting | Which financial statements, finalization returns, and related filings are required? |
A company should designate a person to monitor the acceptance status of its submissions on the electronic tax filing system. Completing a return in the software does not necessarily mean the tax authority has validly received and accepted it. Businesses should also regularly review changes in legislation, check their records, and monitor filing and payment deadlines to avoid missed obligations, reduce errors, and limit the risk of administrative tax penalties.
5. Should a company with no revenue hire an external accounting service?
A business with no revenue is not necessarily required to outsource its accounting. However, if it does not have an appropriate internal accounting team or needs assistance with document management, bookkeeping, and reporting, it may consider PhamConsult’s accounting services to determine a suitable service scope.
There is no general rule requiring every newly established company to hire an external accounting firm.
A company may appoint internal accounting staff or engage a qualified service provider, provided it meets the applicable legal requirements.
Where transaction volumes are low, outsourcing certain accounting tasks may be a practical option, subject to the agreed scope of work. For a company with no revenue, engaging an accounting service with a clearly defined scope may be more cost-effective than maintaining a full-time accounting position, depending on the volume and complexity of transactions.
Conversely, a company with frequent transactions, inventory, receivables and payables, or ongoing cash-flow management needs may benefit from an in-house accountant.
Before engaging a provider, businesses should clarify the service scope, turnaround times, fees, data confidentiality procedures, and responsibility for addressing errors.
6. Frequently asked questions (FAQs)
Does a company with no invoices still need to file tax returns?
The absence of invoices does not automatically remove tax filing obligations. Under Article 11 of Decree No. 252/2026/ND-CP, businesses must determine their filing requirements separately for each tax and assess whether a prescribed exemption applies.
Can a company with no revenue face tax penalties?
Having no revenue is not, in itself, a tax violation. However, penalties may arise if a business fails to meet a filing, submission, or other obligation imposed by law.
Does a company that has not started operating need to hire an accountant?
A company that has not commenced operations does not necessarily need to outsource its accounting. Nevertheless, it must make appropriate arrangements for its accounting functions and comply with applicable obligations. Articles 4, 5, and 29 of the Law on Accounting No. 88/2015/QH13 provide relevant provisions on accounting responsibilities, recording transactions, and preparing financial statements.
Must a company file tax returns while its business operations are suspended?
Under Clause 4, Article 11 and Point c.1, Clause 1, Article 7 of Decree No. 252/2026/ND-CP, a company that has lawfully suspended its operations may qualify for an exemption from filing tax returns during the suspension period. However, if the suspension does not cover the entire filing period or special circumstances apply, its filing obligations must be reassessed.
Must a company established in 2026 pay the business license fee?
A company established in 2026 is not required to submit a business license fee declaration or pay the fee for 2026. Under Clause 7, Article 10 of Resolution No. 198/2025/QH15, as clarified in Tax Department Official Letter No. 645/CT-CS dated January 23, 2026, the collection and payment of the business license fee ceased on January 1, 2026.
7. How PhamConsult can help businesses manage their accounting and tax obligations
PhamConsult provides accounting and tax advisory services, including bookkeeping systems, financial statement reviews, and tax compliance assessments within the scope agreed with each client. Businesses can contact PhamConsult to discuss their operating status and specific support needs.
For newly established companies, the challenge is not limited to completing individual tax returns. They must also identify the correct obligations, maintain supporting documents, and establish accounting processes that remain suitable as the business grows.
PhamConsult can discuss the company’s current accounting records, identify areas where support may be needed, and help determine an appropriate service arrangement.
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Contact: +84 932 103 118
Email: info@phamconsult.com
