Official document No. 3993/TNI-NVDTPC Issued by the Tay Ninh Provincial Tax Department on December 30, 2025, this document is a key guideline for implementing Decree 310/2025/ND-CP. This document focuses on amending and supplementing the regulations in Decree 125/2020/ND-CP on administrative penalties. Effective from January 16, 2026, businesses need to pay particular attention to the changes in the penalty framework and new handling principles. This is an effort by the tax authorities to standardize management and create a transparent mechanism in the era of digital transformation.
Understanding Official Letter No. 3993/TNI-NVDTPC helps accountants and business owners avoid legal risks, especially... corporate income tax Global and electronic invoicing. Data shows that errors in declaration details and invoice timing account for a large proportion of tax audits. Therefore, understanding this document is not only a compliance obligation but also a solution to optimize risk management costs. Let's explore the details of the changes below with MAN – Master Accountant Network.
The scope of regulation and subjects of penalties have been expanded according to Official Letter No. 3993/TNI-NVDTPC.
The key point in Official Letter No. 3993/TNI-NVDTPC is the expansion of the scope of regulation to include revenue from state capital. Accordingly, revenue from state capital investment in enterprises is now included in the list of items subject to penalties if violations of declaration obligations occur. This regulation ensures consistency in public financial management and fairness among different types of enterprises.
Constituent Units and Additional Corporate Income Tax (Pillar 2)
Based on Official Letter No. 3993/TNI-NVDTPC, the additional entity subject to penalties is the "Combined Unit" responsible. corporate income tax declaration and payment According to Resolution 107/2023/QH15, this regulation aims to implement the OECD's global minimum tax rule. Delayed or failure to notify constituent entities will be severely penalized under the new framework in Decree 310/2025/ND-CP.
Control of organizations providing electronic invoicing services.
Official document No. 3993/TNI-NVDTPC also emphasizes tightening management over organizations providing electronic invoice solutions. If the provided solution does not comply with legal principles, this intermediary unit will be directly penalized. This regulation helps protect taxpayers from technical system errors that could lead to unfortunate administrative violations.
Changes to penalty principles: A positive development for taxpayers, according to Official Letter No. 3993/TNI-NVDTPC
In a humane spirit, Official Letter No. 3993/TNI-NVDTPC introduces amendments to help businesses overcome difficulties when committing multiple errors simultaneously. Instead of accumulating penalties, the tax authorities apply a principle of concentrated penalties to alleviate the financial burden in certain specific cases as clearly defined.
| Case of violation | The handling method is based on Decree 310/2025/ND-CP. | Notes from Official Letter No. 3993/TNI-NVDTPC |
| Providing false information on multiple forms across multiple documents (on the same day). | To impose the highest penalty for an offense. | Abolish the aggravating circumstance of "repeated violations".“ |
| Providing false information on multiple forms in one application. | Penalties under Article 16 or 17 of Decree 125 | Focus on tax evasion practices. |
| Invoices were issued at the wrong time multiple times. | One violation will be penalized, with the fine amount based on the number of invoices. | Applicable when it does not result in tax evasion. |
Citing Official Letter No. 3993/TNI-NVDTPC, the abolition of the "repeated violations" circumstance when self-correcting errors in tax indicators on the same day is a significant step forward. This encourages businesses to review and correct errors promptly without fear of multiple penalties, helping to optimize tax management at the unit.
Identifying the latest "Large-scale administrative violations" according to Official Letter No. 3993/TNI-NVDTPC
In section 3 of Official Letter No. 3993/TNI-NVDTPC, the definition of "large scale" has been quantified with specific figures. This is an important basis for accountants to determine the severity of the situation, and thus develop appropriate explanations for the Tay Ninh tax authority and other relevant local tax offices.
Large scale of invoice-related behavior
According to Official Letter No. 3993/TNI-NVDTPC, invoice violations are considered "large-scale" if the number of violating invoices is 10 or more. This regulation applies to errors such as incomplete invoices, incorrect timing, or data transfer violations. The use of the number "10" helps to standardize the implementation of regulations between tax officials and businesses.
Large scale of tax evasion
Regarding tax evasion, Circular No. 3993/TNI-NVDTPC clearly states that the threshold amount is 100,000,000 VND or more. When the amount of tax evaded exceeds this level, the enterprise will face aggravating circumstances or criminal prosecution. This is a stern warning against organized or large-scale tax fraud.
Responsibilities of third parties and related organizations as per Official Letter No. 3993/TNI-NVDTPC
The following section in Official Letter No. 3993/TNI-NVDTPC addresses the coordination between tax authorities and credit institutions. To prevent tax evasion, the law requires relevant parties to provide accurate data. Delayed or inaccurate provision of account information will result in serious administrative penalties for banks.
Official document No. 3993/TNI-NVDTPC affirms that this is the legal basis for strengthening compliance in the financial system. This helps regulatory agencies have sufficient data for verification and transparency in transaction flows. Businesses need to proactively cooperate to avoid problems arising from a lack of consistent information.
Conclude
Official document No. 3993/TNI-NVDTPC is an important guide updating the pivotal changes in tax law in 2026. The document serves both as a deterrent and facilitates legitimate businesses in correcting errors by simplifying penalties for many violations. However, the line between administrative errors and large-scale tax evasion is very thin without thorough understanding.
To ensure absolute safety in the face of changes from Official Letter No. 3993/TNI-NVDTPC, businesses need a professional partner to control risks. MAN – Master Accountant Network is proud to provide this service. auditing services and tax accounting In-depth expertise. We are committed to partnering with businesses to establish standardized internal control systems. Contact MAN today to confidently pursue sustainable growth with our team of experienced professionals.
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Content production by: Mr. Le Hoang Tuyen – Founder & CEO MAN – Master Accountant Network, Vietnamese CPA Auditor with over 30 years of experience in Accounting, Auditing and Financial Consulting.
Frequently Asked Questions about Official Letter No. 3993/TNI-NVDTPC
The penalty documents apply the principle of leniency. If the offense occurred before January 16, 2026, but is reviewed after that date, a lighter penalty will be applied according to the new regulations.
Businesses need to require suppliers to demonstrate compliance with the technical standards of the General Department of Taxation and to commit to taking responsibility if software errors lead to penalties.
According to Official Letter No. 3993/TNI-NVDTPC, you will only be penalized for one instance of false declaration with the highest penalty, excluding aggravating circumstances such as repeated violations. Are Decree 310/2025/ND-CP and Official Letter No. 3993/TNI-NVDTPC applicable retroactively?
How can I verify that an e-invoice provider meets the standards set by Official Letter No. 3993/TNI-NVDTPC?
What are the penalties for incorrectly declaring 5 items on 2 tax returns submitted on the same day?
