A business recently submitted an inquiry to the Ministry of Finance’s electronic portal regarding the implementation timeline of Circular 99/2025/TT-BTC, which outlines the new accounting regime for enterprises. Effective from January 1, 2026, this circular replaces Circular 200/2014/TT-BTC.
The enterprise noted that its fiscal year runs from October 1, 2025, to September 30, 2026, rather than aligning with the calendar year. Consequently, the business sought clarification on whether it must adopt the new accounting regime immediately on January 1, 2026, or if implementation could be deferred until the subsequent fiscal year.
In response, the Accounting and Auditing Supervisory Department of the Ministry of Finance provided the following clarification:
“Article 31, Clause 1 of Circular 99/2025/TT-BTC dated October 27, 2025, stipulates:
1. This Circular shall take effect from January 1, 2026, and apply to fiscal years commencing on or after January 1, 2026…”
Based on this provision, if a company’s fiscal year begins on October 1, 2025, and ends on September 30, 2026, it is not required to implement the accounting regime under Circular 99 as of January 1, 2026. Instead, the new regime will apply to the fiscal year starting October 1, 2026, through September 30, 2027.
Another question: According to Decree 174/2025/NĐ-CP, which details the implementation of the value-added tax (VAT) reduction policy under National Assembly Resolution 204/2025/QH15 dated June 17, 2025, a 2% VAT reduction is applied to certain goods and services taxed at 10% from July 1, 2025, to December 31, 2026. During the effective period of Decree 174/2025/NĐ-CP, does the rental service of E-cloud servers and email management services qualify for the reduced VAT rate of 8%, or will the current 10% rate remain applicable?
The Ministry of Finance addressed this query by referencing the VAT reduction policy outlined in National Assembly Resolution 204/2025/QH15 dated June 17, 2025. Taxpayers are eligible for a VAT reduction on goods and services currently taxed at 10%, excluding those listed in the appendices of Decree 174/2025/NĐ-CP dated June 30, 2025. This decree, effective from July 1, 2025, to December 31, 2026, specifies the following:
Article 1 of Decree 174/2025/NĐ-CP states:
1. A VAT reduction applies to goods and services currently taxed at 10%, excluding the following:
a) Telecommunications, financial activities, banking, securities, insurance, real estate, metal products, and mining products (excluding coal). Detailed in Appendix I.
b) Goods and services subject to special consumption tax (excluding gasoline). Detailed in Appendix II.
c) The VAT reduction for the aforementioned goods and services applies uniformly across import, production, processing, and commercial trading stages.
If goods or services listed in Appendices I and II are exempt from VAT or subject to a 5% VAT rate under the Law on Value-Added Tax, the provisions of the Law on Value-Added Tax shall apply, and no VAT reduction will be granted.
2. VAT reduction rates:
a) Businesses applying the VAT credit method will use an 8% VAT rate for eligible goods and services.
b) Businesses (including households and individuals) applying the VAT calculation method based on a percentage of revenue will receive a 20% reduction in the applicable percentage when issuing invoices for eligible goods and services.
3. Implementation procedures:
a) For businesses under clause 2a, when issuing VAT invoices for eligible goods and services, the VAT rate line should indicate “8%”; the VAT amount and total payable amount by the buyer. Based on the VAT invoice, the selling business declares output VAT, and the purchasing business claims input VAT deductions according to the reduced rate on the invoice.
b) For businesses under clause 2b, when issuing sales invoices for eligible goods and services, the “Total Amount” column should reflect the full amount before reduction, and the “Total Goods/Services” line should show the amount after a 20% reduction in the applicable percentage. A note should be added: “Reduced by… (amount) corresponding to 20% of the VAT calculation percentage under Resolution 204/2025/QH15.”
4. If a business under clause 2a sells goods or provides services subject to different VAT rates, the VAT invoice must clearly indicate the rate for each good or service as per clause 3.
Taxpayers are advised to comply with these regulations based on their business activities.
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