Do You Need a Tax Agent in Vietnam If Your Company Has No Local Accountant?

A tax agent in Vietnam can handle your tax procedures on your behalf: tax registration, filing, payment, finalisation, and files for exemption, reduction or refund. Clause 5, Article 40 of the Law on Tax Administration No. 108/2025/QH15, in force since 1 July 2026, sets out that scope. A tax agent does not remove your duty to keep accounting books. Article 49 of the Law on Accounting requires every company to organise its accounting and either assign people to do it or hire an accounting service. If your company has no local accountant, you need bookkeeping as well as tax filing, from one provider or two.

This guide explains what changed in 2026, what a tax agent may and may not do, how it differs from an accounting service, who qualifies, three common situations, how to appoint one and the mistakes to avoid. It reflects the law as of 29 October 2026 and is written for small offices and new foreign-owned companies in Ho Chi Minh City, Hanoi and elsewhere in Vietnam.

What changed in 2026

The Law on Tax Administration No. 108/2025/QH15, passed on 10 December 2025, took effect on 1 July 2026. It replaces the 2019 law and now defines tax agents and individuals providing tax procedure services in Clause 5 of Article 40.

The Ministry of Finance then issued Circular No. 109/2026/TT-BTC on managing the business of tax procedure services, in force from 24 July 2026. It covers the assessment of professional tax competence for people who practise, the updating of their knowledge, and inspections of providers. For a company choosing a provider, the practical point is that older guides citing the 2019 law and its circulars may no longer describe the current rules.

What a tax agent in Vietnam may do

Under Point c, Clause 5, Article 40 of the 2025 law, the services a tax agent in Vietnam provides to a taxpayer under a contract include the following:

Service	What it covers in practice
Tax registration	Registering the company or individuals for tax and updating registration details
Tax declaration	Preparing and filing monthly, quarterly and annual returns
Tax payment	Carrying out payment procedures on the taxpayer’s behalf
Tax finalisation	Preparing annual finalisation files
Exemption, reduction and refund files	Preparing the files that request them
Other tax procedures	Other procedures with the tax authority on the taxpayer’s behalf
Tax consulting	Advice on how tax rules apply
Accounting services	Provided in accordance with the law on accounting

The same clause says a tax agent must comply with the tax laws when it practises, and is responsible before the law and before the taxpayer for the content of the services it provides (Point d). The contract is what defines which of these services a tax agent in Vietnam actually performs for you.

What a tax agent does not replace

Hiring a tax agent in Vietnam does not end your company’s own obligations. Three of them often surprise new owners.

First, the books. Article 49 of the Law on Accounting requires each accounting unit to organise its accounting, assign people to do the accounting work or hire an accounting service. Tax returns are prepared from those books, so a filing service without bookkeeping behind it has nothing reliable to file from.

Second, the chief accountant role. Vietnamese accounting rules expect a company to appoint a chief accountant, or a person in charge of accounting where none is appointed yet, and allow that role to be filled through a service provider. Whether a provider can take the role depends on the provider and the person, so confirm it in writing.

Third, the company remains the taxpayer. The agent answers to you and to the law for the quality of its work, but the tax owed, the deadlines and the documents behind each figure stay with the company. In our professional view, the owner should still see each return before it is filed and keep control of the e-tax account and the digital signature.

Tax agent in Vietnam or accounting service

The two services overlap, and the law lets a tax agent provide accounting services under the accounting rules. The table compares the core of each, so you can see which one your company is missing.

Aspect	Tax agent	Accounting service
Main output	Tax registration, returns, payments, finalisation and other tax procedures	Accounting vouchers, books, financial statements and management reports
Legal basis	Clause 5, Article 40, Law on Tax Administration No. 108/2025/QH15	Law on Accounting No. 88/2015/QH13 and its implementing rules
Needed when	You need someone to handle procedures and contact with the tax authority	You have no one to keep the books or prepare financial statements
Works from	Figures and documents from the books	Invoices, contracts, bank statements, payroll
Enough on its own for a company with no accountant	Usually not, unless the contract also covers accounting	Covers the books; tax filing is often included but check the scope

For a company with no local accountant, the usual answer is one provider that does both under one contract, or an accounting service plus a separate tax agent in Vietnam. Two providers can work, but someone must own the handover of figures each month.

Who can act as a tax agent in Vietnam

Point a, Clause 5, Article 40 defines a tax agent as an enterprise established under the law that has at least two people who meet the standards for providing tax consulting services, working full time at the enterprise. Household businesses and individuals who meet those standards may also provide tax procedure services (Point b).

Circular No. 109/2026/TT-BTC sets the conditions to take part in the assessment of professional tax competence. Article 4 opens it to Vietnamese citizens and foreigners permitted to reside in Vietnam for 12 months or more who have full civil capacity and a university degree in economics, tax, finance, accounting, auditing or law, or another degree with enough of those subjects in the course.

When you compare providers, ask for evidence that the firm operates as a tax agent and for the names of the qualified staff who will work on your file. In our professional view, a provider that hesitates to show either is a risk, whatever the price.

Three common situations

These are the situations we see most often when a company asks whether it needs a tax agent in Vietnam.

A newly licensed foreign-owned company with no staff yet. It needs bookkeeping from day one, the first returns, e-invoices and payroll set up. One provider for accounting and tax is usually the simplest choice until the company hires its own accountant.

A company with an in-house bookkeeper who is not confident on tax. The books are kept internally; a tax agent reviews returns, prepares the annual finalisation and handles questions from the tax office. The split must be written down so the bookkeeper knows what to send and when.

A company whose parent’s accountant abroad wants to keep the books. The statutory books must be kept in Vietnamese, with a foreign language alongside if used (Clause 1, Article 11 of the Law on Accounting), and the returns are filed in Vietnam. A local provider, often acting as both accountant and tax agent, keeps the statutory layer while the parent keeps its own reporting.

How to appoint a tax agent in Vietnam

A short, ordered set-up avoids most problems later:

• Define the scope in the contract: which returns, which taxes, finalisation, refunds, contact with the tax office, and whether accounting is included.
• Agree who holds the e-tax account and the digital signature, and how filings are approved before submission.
• Set a monthly calendar: when documents reach the agent, when drafts come back, and the filing deadlines.
• Agree the documents the agent needs from the books and who sends them.
• Ask how the agent will tell you about notices or letters from the tax authority, and how fast.
• Keep copies of every filed return and payment in the company’s own records.

Whether the tax authority must be notified of the contract with a tax agent under the 2026 rules is a point to confirm with the provider when you sign.

Questions to ask before you sign

Before you sign with a provider, these questions show quickly whether the scope fits a company with no local accountant:

• Does the contract cover bookkeeping and financial statements, or tax procedures only?
• Who on your team meets the standards for tax consulting services, and who will handle our file day to day?
• Who files the returns, and how do we approve them before submission?
• How do you tell us about notices, requests for explanation or inspections from the tax office?
• What do you need from us each month, and by which date?
• What happens to our files, e-tax access and digital signature if we change providers?

A provider that answers each of these in writing, before the first month starts, is easier to work with when a question from the tax office arrives.

5 mistakes to avoid when using a tax agent in Vietnam

These are the mistakes worth avoiding, in our professional view:

• Hiring a tax agent and assuming the books are kept, when the contract covers filing only.
• Handing over the e-tax account and digital signature with no approval step before returns are filed.
• Choosing a provider without asking who on its team is qualified and who will work on your file.
• Sending documents late in the month and expecting returns to be right by the deadline.
• Relying on guides that still cite the 2019 law and circulars replaced in 2026.

Frequently asked questions

Is a company in Vietnam required to use a tax agent? The rules cited here describe what a tax agent may do under a contract; they do not require a company to hire one. A company can file its own returns if it has the people to do it.

Can a tax agent in Vietnam also keep our books? The 2025 law includes accounting services, provided in accordance with the law on accounting, in the services a tax agent may offer (Point c, Clause 5, Article 40). Check that the contract covers bookkeeping and financial statements, not only tax filing.

Who is responsible if a return filed by the agent is wrong? The agent is responsible before the law and before the taxpayer for the content of its services (Point d, Clause 5, Article 40). The company remains the taxpayer for the tax owed, so the contract should say how errors are corrected and who bears the cost.

Can a foreigner work as a tax practitioner in Vietnam? Circular No. 109/2026/TT-BTC allows foreigners permitted to reside in Vietnam for 12 months or more, who meet the other criteria, to take part in the competency assessment (Article 4).

Does a representative office need a tax agent? A representative office has its own tax duties, for example on staff salaries. Whether it needs an agent depends on who can handle those filings; the rules cited here do not require one.

How Pham Consult supports companies as a tax agent in Vietnam

Pham Consult is a registered tax agent and supports companies in their dealings with the tax authorities. Our tax agent services include tax registration for enterprises and tax codes for individuals, monthly, quarterly and annual declarations, support for tax finalisation, review of tax returns prepared by companies, preparation of tax refund files, assessment of tax compliance and liaison with the tax authorities on the company’s behalf. Through our accounting services we also keep the books and prepare financial statements, so one team can cover both for a company with no local accountant.

More detail is on our page on tax agent services in Ho Chi Minh City. Pham Consult works from offices in Ho Chi Minh City and Hanoi.

Talk to a licensed tax agent about the right split between accounting and tax for your company.

Hotline: +84 909 660 105

Email: info@phamconsult.com

This article is general information as of 29 October 2026 and is not tax or legal advice for a specific case. Tax rules change; check the current law before you rely on it.