Beneficial ownership disclosure Vietnam: New tax rules for foreign entities
As of 1 July 2026, branches and representative offices of foreign companies that register directly with the Vietnamese tax authorities are required to disclose information regarding the legal and beneficial owners of their foreign parent companies. Ecovis consultants explain exactly what this entails and which services companies should entrust to experts.
If a branch or representative office already possesses a tax identification number, the question arises as to the extent to which the Vietnamese tax authorities hold complete and accurate information regarding the individuals or entities that ultimately own or control the foreign parent company. According to Circular No. 90/2026/TT-BTC, this information must be disclosed using Form BK07-DKT.
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Who are the “legal owner” and “beneficial owner”
These terms can often lead to confusion, as they are not the same. Official Dispatch No. 4937/CT-NVT provides the following guidance:
- Legal owner: The organisation or individual formally holding equity, shares, or an equivalent ownership interest in the parent company, under the law of the country where the parent was incorporated. This is usually identified directly from the parent’s shareholder register.
- Beneficial owner: The individual(s) who, in substance, actually own or control the parent company, even without being a direct shareholder. This is generally an individual who holds, directly or indirectly, 25% or more of charter capital, or who otherwise holds real controlling power. If no such individual can be identified, then the parent’s legal representative must be named.
Because beneficial ownership can run through several layers of intermediary companies, identifying this person usually takes time.
When is form BK07-DKT required
Form BK07-DKT must be submitted when registering for tax for the first time or updating registered tax information. It may also be required when the tax authority reviews existing records and requests additional information.
For offices with an existing tax code and no relevant changes, there is currently no general deadline for proactive filing. However, representative offices in Ho Chi Minh City have already begun receiving requests to submit the form under Notice No. 27879/TB-TPHCM dated 27 July 2026.
We support companies in correctly implementing the new mandatory disclosure regulations.
Vu Manh Quynh, Attorney-at-Law, Managing Partner, ECOVIS Vietnam Law, Ho Chi Minh City, Vietnam
How to file form BK07-DKT
Form BK07-DKT is generally submitted electronically via the National Public Service Portal (https://dichvucong.gdt.gov.vn/). Where electronic submission is not feasible, the application may alternatively be filed directly with the relevant managing tax authority or sent by post.
What action should companies take
Ownership disclosure can be technical. Companies should therefore seek expert advice on the following points, for example, in order to correctly comply with the regulations applicable since July 2026.
- Reviewing the information and supporting documents required for Form BK07-DKT
- Preparing Form BK07-DKT and the relevant filing dossier
- Following up with the tax authority regarding any request for clarification or supplementary documents
