Attention! Vietnam Has Not Yet Fully Restored Its Tax Compliance Status — 2028 Will Be the Key Milestone

On October 9, 2026, the Council of the European Union formally decided to remove Vietnam from the EU list of non-cooperative jurisdictions for tax purposes (Annex I, commonly known as the “tax blacklist”). Vietnamese Ministry of Foreign Affairs spokesperson Pham Thu Hang welcomed the decision the following day.

According to the Council's announcement, Vietnam has been moved to Annex II, commonly known as the “grey list.” This list covers jurisdictions that have committed to reforms and are cooperating with international partners but have not yet fully met the required compliance standards. Vietnam remains under observation by the Global Forum on Transparency and Exchange of Information for Tax Purposes (the “Global Forum”), pending a reassessment.

Why Vietnam Was Placed on the Tax Blacklist

In November 2025, the OECD Global Forum published Vietnam's second-round peer review report, assigning the country an overall rating of “Non-Compliant.”

The report identified deficiencies in confidentiality procedures, the timeliness of information provided to partner jurisdictions, and oversight of ownership, accounting and banking information. Although Vietnam's tax authorities have broad powers to access domestic information, those powers could not be fully exercised for international tax information exchange purposes.

Based on this rating, the EU added Vietnam to its tax blacklist on February 17, 2026.

Corrective Measures Vietnam Has Taken in Eight Months

The Vietnamese government characterized the problems as technical compliance deficiencies and subsequently launched a series of systematic reforms.

On May 27, 2026, the Vietnamese government issued Decision No. 948/QD-TTg, introducing the National Action Plan for Fulfilling Tax Information Exchange Obligations. The plan sets out 25 specific actions across five areas: institutional improvement, enforcement mechanisms, infrastructure and data, monitoring and inspection, and training and capacity building.

The plan, signed by Deputy Prime Minister Nguyen Van Thang, aims to provide a basis for the OECD and the EU to reassess Vietnam's compliance status.

From July 20 to 24, 2026, the Global Forum Secretariat held a five-day technical working meeting in Hanoi with Vietnam's Ministry of Finance, State Bank, Ministry of Public Security, Ministry of Justice and Ministry of Foreign Affairs.

The discussions focused on the availability and accessibility of beneficial ownership information, accounting records and banking information. During the meetings, the State Bank of Vietnam and the tax authorities reached an agreement on a data-sharing mechanism involving the National Credit Information Centre (CIC). Following the meetings, Vietnam formally submitted a request to the Global Forum for an in-depth assessment.

To meet international compliance requirements, Vietnam also accelerated amendments to several regulations.

On July 24, 2026, the government issued Resolution No. 66.23/2026/NQ-CP, targeting implementation barriers under the Anti-Money Laundering Law to help fulfil international tax information exchange obligations.

Vietnam also amended regulations related to business registration, strengthening the legal framework governing ownership and beneficial ownership information.

Timeline and Next Steps

• October 2025: The Global Forum adopted Vietnam's peer review report, assigning an overall rating of “Non-Compliant.”
• February 17, 2026: The EU added Vietnam to its tax blacklist.
• May 27, 2026: Vietnam issued its national action plan under Decision No. 948/QD-TTg.
• July 20–24, 2026: The Global Forum's technical assistance team visited Vietnam.
• July 24, 2026: Vietnam submitted a request for an in-depth assessment.
• October 9, 2026: The EU removed Vietnam from the blacklist and transferred it to the grey list.
• Second quarter of 2028 (expected): The Global Forum is expected to begin a reassessment.
• February 2027 (expected): The Council of the EU is scheduled to conduct its next list update.

Vietnam is currently under observation for conditional compliance. Its grey-list status indicates that outstanding issues remain in meeting international tax transparency standards, although the country has received provisional recognition from international assessment bodies for its reform efforts.

Industry Implications

Vietnam's removal from the blacklist essentially marks a shift in its status in the field of tax information exchange—from “non-cooperative” to “undergoing reform.”

For freight forwarders and cargo owners engaged in import and export business involving Vietnam, two points deserve attention.

First, Vietnam is expected to remain on the grey list until the reassessment process is completed in 2028. During this period, EU member states may still take a cautious approach to transactions involving Vietnam under their respective national laws. Businesses conducting cross-border related-party transactions with Vietnamese companies, or operating subsidiaries or branches in Vietnam, should pay close attention to the tax provisions in their contracts.

Second, tax transparency reforms will gradually affect corporate information management. Vietnam's efforts to establish data-sharing mechanisms between banks and tax authorities, together with its beneficial ownership disclosure requirements, indicate that companies operating in Vietnam will face increasingly stringent financial transparency expectations.

For freight forwarders that rely on Vietnamese suppliers or customers, checking the tax compliance status of business partners will increasingly become part of routine risk management.

Businesses should closely monitor implementation guidelines issued by Vietnam's Ministry of Finance and tax authorities, as well as periodic updates from the Global Forum on Vietnam's compliance status. Companies with cross-border transactions involving Vietnam may wish to consult professional tax advisers to assess potential implications.