On 17 February 2026, the Council of the European Union placed Viet Nam on Annex I of the EU list of non-cooperative jurisdictions for tax purposes.
This development is serious.
But it is also manageable — and resolvable within months.
Importantly, the listing does not relate to harmful tax regimes or aggressive tax competition. It concerns technical aspects of the OECD Exchange of Information on Request (EOIR) framework — primarily transparency, access to information, and administrative efficiency.
With decisive and coordinated action, Viet Nam can secure removal from Annex I at the next EU review cycle in October 2026.
Below is a constructive, transparent and solution-oriented roadmap.
The Objective
Removal from Annex I in October 2026
through rapid technical alignment with OECD standards and close cooperation with EU counterparts.
Whole-of-Government Coordination Is Essential
Lead Authority:
Ministry of Finance (MOF)
Operational Lead:
General Department of Taxation (GDT)
Key Supporting Bodies:
- Ministry of Planning and Investment (corporate & beneficial ownership registry)
- State Bank of Viet Nam (banking information access)
- Ministry of Justice (legal alignment)
- Ministry of Foreign Affairs (EU engagement)
- Prime Minister’s Office (strategic oversight)
- Ministry of Finance
This must be treated as a coordinated national priority.
Phase 1 (Immediate – Next 30 Days)
1️. Establish a High-Level Inter-Ministerial Task Force
Clear mandate: removal from Annex I by October 2026.
2️. Conduct a Rapid Gap Analysis
Focus areas:
- Beneficial ownership transparency
- Access to accounting records
- Access to banking information
- Timeliness of EOIR responses
- Enforcement mechanisms
Outcome: A clear technical compliance matrix.
Phase 2 (April–July 2026): Fast-Track Corrective Measures
The Government does not need to wait for lengthy legislative cycles.
Swift action is possible through Decrees, Circulars and Directives.
✔ Strengthen Beneficial Ownership Transparency
- Centralized and updated BO registry
- Mandatory reporting and updating obligations
- Direct tax authority access
- Administrative sanctions
- Compliance audits
✔ Ensure Direct Access to Banking Information
- Clear authority for tax administration
- Defined response timelines for banks
- Secure digital request channel
- Penalties for delayed cooperation
✔ Guarantee Availability of Accounting Records
- Clarified retention requirements
- Digital record obligations
- Sanctions for non-compliance
✔ Improve EOIR Administrative Efficiency
- Dedicated EOIR unit within GDT
- Case tracking dashboard
- Strict internal response timelines
Phase 3 (July–September 2026): Demonstrate Implementation
Legislation alone is not sufficient.
The EU and OECD expect evidence of practical enforcement.
Actions should include:
- Publication of EOIR response statistics
- Risk-based beneficial ownership compliance reviews
- Public confirmation of enforcement steps
- Structured technical dialogue with OECD and EU bodies
Transparency builds credibility.
Diplomatic Engagement
Parallel engagement with the EU Code of Conduct Group and the European Commission is essential.
Messaging should emphasize:
- Full commitment to OECD standards
- Technical nature of the issue
- Corrective measures already underway
- Clear timeline toward October 2026 resolution
Constructive, forward-looking dialogue is key.
Proposed Timeline
March 2026 – Task force established
April 2026 – Gap analysis completed
May–June 2026 – Decrees & circulars issued
July 2026 – EOIR unit fully operational
August 2026 – Enforcement & statistics published
September 2026 – Technical engagement with EU
October 2026 – Target: Removal from Annex I
Strategic Perspective
This situation is not a structural tax policy issue.
It is a technical compliance matter — and therefore solvable.
Handled correctly, it can become an opportunity to:
- Modernize transparency systems
- Strengthen inter-agency coordination
- Reinforce investor confidence
- Demonstrate Viet Nam’s commitment to international standards
Swift action today prevents reputational risk tomorrow.
Viet Nam has successfully exited EU monitoring mechanisms before.
With coordinated leadership and decisive implementation, October 2026 is a realistic and achievable milestone.
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Please do not hesitate to contact Dr. Oliver Massmann under [email protected] if you have any questions or want to know more details on the above. Dr. Oliver Massmann is the General Director of Duane Morris Vietnam LLC.
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#Vietnam #EU #TaxTransparency #OECD #InvestmentClimate #PolicyReform #InternationalCooperation