Official Letter 6936/CT-QLTT: Tax Department Standardises Risk-Based Handling of VAT Refund Claims

On 18 September 2026, the Tax Department issued Official Letter No. 6936/CT-QLTT to provincial and municipal tax offices. The letter sets out uniform guidance on the handling of value-added tax (VAT) refund claims. It is accompanied by a guidance note published for taxpayers.

The letter is issued on the basis of Articles 18 and 33 of Law on Tax Administration No. 108/2025/QH15, Article 30 of Decree No. 252/2026/ND-CP, Articles 48 and 49 of Circular No. 89/2026/TT-BTC, and Clause 3, Article 1 of Law No. 149/2025/QH15. It is the first significant VAT refund directive since the new tax administration framework took effect on 1 July 2026.

Below are the key points and W&A's observations:

1. A risk alert is not a finding of non-compliance

2. Review is confined to the risk identified

3. Risks at F2, F3 do not automatically pass to the buyer

4. The seller's VAT declaration and payment

5. Review of pending claims

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W&A Newsletter on OL 6936 regarding VAT Refund-EN.pdf

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Official Letter 6936 marks a clear shift in the tax authority's approach, from controlling refunds at the level of the whole claim to controlling them by amount and within the scope of identified risk. If implemented consistently, the letter will provide a meaningful basis for preventing entire claims from being delayed because of a single invoice or a supplier deep within the supply chain.

W&A stands ready to assist businesses with supplier risk reviews, preparation of refund claims, explanations and engagement with the tax authority, and resolution of pending refund claims.