Ministry Of Finance Issues Circular No. 94/2025/TT-BTC: Important Update For The Tax Sector & Enterprises

On October 14, 2025, the Minister of Finance officially issued Circular No. 94/2025/TT-BTC, amending and supplementing several provisions of Circular No. 80/2021/TT-BTC (guiding the implementation of the Law on Tax Administration and Decree No. 126/2020/NĐ-CP) and amending, supplementing the templates attached to Circular No. 40/2021/TT-BTC (related to value-added tax, personal income tax, and tax administration for business households and individuals).

This Circular takes effect from October 14, 2025.

Below are the key highlights, impacts, and important notes that enterprises, individuals, and tax authorities need to be aware of.

📌 KEY HIGHLIGHTS OF CIRCULAR NO. 94/2025/TT-BTC

1. Clarifying the authority for receiving and processing tax refund dossiers

Circular 94 revises Clause 2, Article 27 of Circular 80/2021/TT-BTC, specifying that the tax authority directly managing taxpayers is responsible for receiving and processing tax refund dossiers (except for cases assigned to provincial-level tax authorities).

For investment projects, the Provincial/City Tax Department where the project is declared is responsible for receiving and resolving the tax refund dossier.

Adds responsibility for processing uncredited input VAT refund dossiers for business establishments in cases of dissolution or bankruptcy.

2. Abolishing certain outdated regulations

Abolishes Clause 3, Article 36 and Clause 2, Article 38 of Circular 80/2021/TT-BTC.

Provisions related to sending tax refund decisions, offset refunds, and documents to local tax branches for monitoring have been removed or simplified.

3. Adding the term “Personal Identification” & expanding its use in forms

In all tax declaration, refund, and personal income tax forms, terms such as “ID Card”, “Citizen ID”, or “Identity Card” are replaced or supplemented with “Personal Identification”.

New data fields are added:

• [02a] – Personal Identification Number in Form 01/MGTH;

• [05a] – Personal Identification Number in Forms 02/KK-TNCN, 02/QTT-TNCN, 04/CNV-TNCN, 04/ĐTV-TNCN, 04/NNG-TNCN, 03/TKTH-SDDPNN.

Forms in Circular 40/2021/TT-BTC (for business households and individual businesses) are also revised to include “Personal Identification” fields replacing “ID Card” and “Citizen ID”.

Specifically, forms such as 01/CNKD, 01/TTS, 01-1/BK-XSBHĐC, 01/TKN-CNKD will be updated according to the new Circular.

📆 EFFECTIVE DATE AND TRANSITIONAL PROVISIONS

• Effective date: From October 14, 2025 onward.

• Transitional provisions:
  For VAT refund dossiers received before January 1, 2025 but not yet resolved due to verification or pending responses from other agencies, the current tax authority handling the case will continue to process it under the new regulations.
  New tax declaration obligations and templates apply to tax periods starting from October 14, 2025.

🏢 IMPACTS ON STAKEHOLDERS

1. For enterprises & business households/individuals

• Must review and update all forms and declaration systems to ensure “Personal Identification” information is correctly filled according to new data fields.

• If there are pending refund dossiers, monitor whether the tax authority continues processing them under the new guidelines.

• Particularly in cases of dissolution or bankruptcy with uncredited input VAT, coordinate closely with the managing tax authority to complete refund procedures under the revised regulations.

2. For tax authorities at all levels

• Must implement a unified process for receiving and handling tax refund dossiers, avoiding overlaps between local tax branches and provincial departments.

• Issue internal guidelines on transitional cases to ensure taxpayers’ rights are protected.

• Update electronic management systems, e-forms, and e-transactions to support “Personal Identification” declarations.

3. On administrative management & transparency

• Using “Personal Identification” instead of various ID types helps standardize data, reduce confusion, and minimize errors across tax administration systems.

• The reform in refund dossier authority aims to avoid delays and overlapping responsibilities among tax levels.

• This Circular is another step toward improving the legal framework for taxation, enhancing transparency and efficiency in tax management.

ALTAS is committed to supporting investors and businesses during this period of volatility. Please contact us at contact@altas.vn to discuss your specific needs.