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TAX AUDIT DURATION FROM 2026
KEY CHANGES UNDER DESICION NO. 1161/QD-CT
From 2026, regulations on the duration of tax audits conducted at taxpayers’ premises have undergone significant changes, particularly for enterprises engaged in related-party transactions. Compared with the previous regulations, the permitted audit period has been extended, with specific provisions introduced for enterprises with related-party transactions.
1. Tax Audit Duration under the Previous Regulations
Under the previous regulations of the Law on Tax Administration 2019, a tax audit conducted at the taxpayer’s premises was required to be completed within 10 working days from the date of announcement of the tax audit decision.
In cases where the scope of the audit was broad or the contents were complicated, the competent authority could extend the audit once for a period of no more than 10 working days.
Accordingly, where an extension was granted, the total maximum audit period under the previous regulations was 20 working days.
2. Tax Audit Duration under the New Regulations
Under the new regulations applicable from 1 July 2026, the tax audit period at the taxpayer’s premises has been extended.
The applicable periods are as follows:
| Type of taxpayer | Initial audit period | Extension | Maximum total period if extended |
|---|---|---|---|
| Ordinary enterprises | Up to 20 days | Once, up to 20 days | 40 days |
| Enterprises with related-party transactions | Up to 40 days | Once, up to 40 days | 80 days |
The tax audit period is calculated from the date on which the tax audit decision is announced.
Accordingly, compared with the previous regulations, the standard audit period for ordinary enterprises has increased from 10 working days to 20 days, while enterprises with related-party transactions may be subject to a longer audit period of up to 40 days before any extension.
3. Specific Provision for Enterprises with Related-Party Transactions
One of the notable changes under the new regulations is the introduction of a specific audit period for enterprises engaged in related-party transactions.
For such enterprises, the tax audit period is limited to 40 days from the date of announcement of the audit decision and may be extended once for a period of no more than 40 days.
Therefore, where an extension is granted, the total audit period may reach 80 days.
4. Periods Excluded from the Tax Audit Duration
The tax audit period is calculated based on the actual period of the audit as prescribed by law. Certain periods are not included in the statutory tax audit duration, including periods during which the audit is suspended in accordance with applicable regulations.
Therefore, enterprises should distinguish between the statutory audit period and the overall period from the announcement of the audit decision until the actual completion of the audit.
5. Transitional Provisions under Decision No. 1161/QD-CT
Decision No. 1161/QD-CT of 2026 promulgates the Tax Audit Procedures and replaces Decision No. 970/QD-TCT of 2023.
The transitional provisions
- Tax audit decisions issued before 1 July 2026: continue to follow the previous regulations.
- Tax audit decisions issued from 1 July 2026 but before Decision No. 1161/QD-CT takes effect: follow the new Law on Tax Administration; once Decision No. 1161/QD-CT takes effect, any remaining steps that have not yet been performed will be carried out under the new procedures.
- Tax audit decisions issued from the effective date of Decision No. 1161/QD-CT: the new Tax Audit Procedures apply in full.
