Resolving obstacles to individual refund amounts
In the final months of the year, the need to return tax refund funds to production and business activities must be balanced with the task of safeguarding the State budget. The Ministry of Finance has identified the key reform priority as handling each transaction and each portion of a refund claim separately, preventing obstacles affecting part of a claim from delaying the entire amount that already qualifies for a refund.
According to Ministry of Finance figures, as of September 30, 2026, a total of 14,668 VAT refund decisions had been issued nationwide, involving 149.463 trillion VND (5.78 billion USD). This represented 86.4% of the 2026 refund budget estimate of 173 trillion VND (6.69 billion USD). In the same period of 2025, 12,736 refund decisions were issued, involving 102.379 trillion VND (3.96 billion USD).
The total refund amount therefore increased by around 46%, or more than 47 trillion VND (1.82 billion USD), year on year. This result indicates a substantial increase in the value of refunds processed. However, assessing whether processing times have improved also requires consideration of progress across different categories of claims, the proportion settled on time and the number of outstanding cases.
Export-related VAT refunds continued to account for the largest share, at approximately 125 trillion VND (4.84 billion USD), or around 84% of the total. Refunds for investment projects accounted for 791 decisions, worth nearly 23.5 trillion VND (909.27 million USD). Other cases, including tax incentives and diplomatic exemptions, accounted for 490 decisions, worth nearly 1 trillion VND (38.69 million USD).
This breakdown shows that VAT refunds are directly linked to the capital available to export businesses and investment projects. Therefore, alongside the total amount refunded, the timely processing of eligible claims needs to remain a priority in the reform process.
In recent years, the Ministry of Finance has focused on improving policies, legislation and professional procedures, while directing tax authorities to adopt a management approach that ensures fast and compliant processing for taxpayers with good compliance records. Risk management and efforts to prevent and combat fraud have also been strengthened to safeguard State budget funds used for tax refunds.
According to the ministry, the legal framework continues to be refined through the Law on Tax Administration and its implementing documents. This provides a basis for classifying taxpayers by compliance level, applying preferential treatment, automating refunds using data and managing risks. The intended shift is towards identifying the portion of a claim eligible for a refund and separating it from the portion that presents risks and requires inspection or verification.
During implementation, claim processing progress is regularly monitored, with responsibility assigned to heads of relevant units. Outstanding and long-delayed cases are being reviewed and addressed as a priority. The stages of receiving, classifying, processing, appraising, approving and returning results are gradually being digitised and automated, with activities recorded in the system.
Nevertheless, some claims still take a long time to process. According to the Ministry of Finance, the main obstacles arise in cases involving transactions through multiple intermediaries, several businesses or different localities, or those displaying risk indicators that require inspection and verification.
Nguyen Thi Thu Huong, Deputy Head of the Professional Affairs Division under the Tax Department, identified three main reasons for delays: businesses failing to prepare complete and accurate documentation for claims subject to pre-refund inspection; claims presenting risk indicators that require verification; and policy issues involving multiple sectors that require consultation before refunds can be approved.
At a recent conference on VAT refunds organised by the Tax Department, a representative of the Foreign-Invested Enterprises Association reported that verifying chains of input invoices could take a long time when suppliers were located in different localities. The association proposed that if only certain invoices raised suspicions, tax authorities should withhold the corresponding amount for verification rather than retain the entire refund claimed for a project.
Some regulations on tax deduction and refund eligibility remain complex, while management data are fragmented. Information sharing between tax authorities and customs, banks, police and other relevant agencies is not yet sufficiently comprehensive or timely. These limitations highlight the need to simplify procedures while improving data matching and verification capabilities.
Preparing to pilot data-driven tax refunds
One notable milestone planned for the final months of the year is a pilot scheme in December 2026 to automatically determine the amounts eligible for refunds, paving the way for official implementation from 2027. This is part of the Ministry of Finance’s broader package of measures to digitise processes, automate operations and manage risks at the transaction level.
Under this approach, electronic invoice data, tax declarations, customs records, payment information and other relevant sources will be increasingly interconnected and cross-checked. On this basis, tax authorities will determine which amounts qualify for immediate refunds, which require explanations or verification, and which involve risks warranting inspection.
The requirement is to “ensure that risks associated with part of a transaction do not delay refunds for the entire amount already eligible for a refund”. This is a key feature of the new approach, which links control measures to specific amounts and transactions while enabling eligible refunds to be processed promptly.
Mai Son, Deputy Director General of the Tax Department, has instructed tax authorities to provide businesses with clear information on the status of their claims. Where a claim does not yet qualify for a refund, the authorities must specify the reasons, the amount eligible for a refund, the amount not yet refundable and the matters requiring verification.
To implement this approach, the Ministry of Finance has identified three key groups of measures. The first is to continue improving policies, simplifying procedures and accelerating refunds for compliant taxpayers. Issues concerning deduction and refund eligibility will be reviewed and addressed, while claim documentation will be simplified by eliminating duplicate information and documents.
One measure directly related to compliance costs is to stop requiring taxpayers to resubmit information already held by State agencies. Implementing this requirement depends on the ability to retrieve and use existing data during claim processing, helping businesses avoid repetitive administrative work.
Taxpayers will be classified according to their compliance levels and risk profiles so that appropriate procedures can be applied. For those with good compliance records, the priority is to shorten processing times while combining this with post-refund inspections based on risk management. This approach requires clear classification criteria and up-to-date data to support assessments.
The second group of measures focuses on digitisation and automation. Alongside data integration, the ministry is working to refine its risk assessment criteria in preparation for the December pilot scheme. The pilot will provide a basis for official implementation from 2027.
Regarding the development of an automated refund process, Mai Son said data would be connected automatically, while the system would analyse, cross-check and classify risks. Subjective intervention would be minimised in stages that could be handled by the system, allowing tax officials to focus on cases presenting genuine risks that require inspection and verification.
The third group of measures aims to improve fraud control and strengthen accountability for implementation. Inspections will shift away from examining individual claims and businesses in isolation towards analysing transaction chains, invoice chains and cash flows, with a focus on businesses, transactions and links displaying risk indicators.
Combining tax declaration data, electronic invoices and information from relevant agencies and organisations will help identify risks across interconnected transactions. Therefore, stronger data sharing between tax authorities and customs, banks, police and other relevant agencies is an essential part of the procedural reform.
Accountability among heads of relevant units will also be linked to processing times, the proportion of claims settled on time, outstanding cases and the degree of automation. These indicators will help monitor actual performance and identify bottlenecks requiring corrective action.
The Ministry of Finance aims to measure reform by the actual time and costs involved and the level of convenience experienced by citizens and businesses. For VAT refunds, this means promptly refunding eligible amounts, clearly addressing portions requiring verification and reducing the number of long-delayed claims. The pilot scheme planned for the end of the year is a preparatory step towards putting data-driven, risk-based management into practice and supporting the flow of capital into production and business activities.
