Ho Chi Minh City Intensifies Personal Income Tax Review for High-Income Earners – Who Will Be Audited?

The Ho Chi Minh City Tax Department is implementing a plan to intensify the review, reconciliation, and collection of personal income tax (PIT) from high-income individuals and those at risk of discrepancies between actual income and declared income.

The objective of this review is not to impose new taxes but to ensure that taxpayers fully and accurately declare their income and fulfill their obligations in accordance with the Law on Tax Administration and the Law on Personal Income Tax.

1. Why is the tax authority intensifying its review?

According to the infographic, the review aims for three main objectives:

• Enhancing tax law compliance awareness among high-income individuals.
• Reducing state budget revenue loss by detecting undeclared or under-declared income.
• Strengthening coordination among management agencies, thereby improving tax management efficiency for high-income professions.

This also reflects the trend of digital transformation in tax administration, where data from multiple sources is connected and automatically reconciled.

2. Which professional groups are being primarily reviewed?

According to the infographic, the tax authority focuses on professional groups with the potential for high income or multiple income sources, including:

• Doctors;
• Pharmacists;
• Lawyers;
• Notaries;
• Real estate brokers;
• Lecturers;
• Teachers;
• Sports coaches;
• Actors/Actresses;
• Other independent professionals.

This is not a list of violating professions, but rather a group of high-income professions or those with the potential for revenue from multiple sources, leading to a risk of incomplete declaration.

3. Where does the tax authority collect data from?

A notable point is that the tax authority does not solely rely on self-declared tax returns but also reconciles information from various other sources.

According to the infographic, data is compiled from:

Professional licensing lists

For example:

• lawyer practice certificates;
• medical examination and treatment practice certificates;
• real estate broker licenses;
• notary practice licenses.

This information helps the tax authority identify individuals operating in each field.

Professional management organizations

Including:

• Bar Associations;
• Notary Associations;
• Professional associations;
• other specialized management organizations.

Tax finalization records

The tax authority reconciles:

• finalization declarations;
• tax paid;
• outstanding debts;
• taxpayer's declaration history.

Bank transaction data (if necessary)

In some cases for inspection or audit purposes as stipulated by law, the tax authority may coordinate with banks to verify cash flows and reconcile them with declared income.

Access to this information must be carried out according to procedures, authority, and legal grounds, and is not automatically collected in all cases.

4. How does the tax review and collection process work?

According to the infographic, the process consists of 06 steps.

Step 1. Data collection

Information is compiled from various sources to build a tax management profile.

Step 2. Reconciliation and analysis

The tax authority conducts:

• comparison of declared income;
• reconciliation of revenue;
• analysis of discrepancies between collected data and tax declaration records.

Step 3. Coordinate cash flow verification (if necessary)

If there are signs of significant discrepancies or a need to clarify income sources, the tax authority may coordinate with banks and relevant agencies to verify in accordance with legal provisions.

Step 4. Request for explanation

If signs of incomplete declaration are found, the tax authority will:

• send an invitation letter;
• request additional documents;
• request an explanation of income sources.

This is the stage for taxpayers to provide supporting documents and explain their income.

Step 5. Determine tax obligations

After reviewing the explanation documents, the tax authority will determine:

• additional tax payable (if any);
• late payment interest;
• or conclude that the taxpayer has fulfilled their obligations correctly.

Step 6. Tax collection (if violations are found)

If an act of under-declaration or non-declaration of taxable income is determined, the tax authority will proceed with collection as stipulated.

In addition to the tax payable, individuals may also be subject to:

• late payment interest;
• administrative penalties for tax violations (if sufficient grounds exist under law).

5. What should individuals do to mitigate risks?

According to the infographic, taxpayers should proactively:

Review all income sources

Including:

• salaries;
• wages;
• income from professional activities;
• income from multiple paying entities;
• other taxable income.

Reconcile documents

Check:

• invoices;
• contracts;
• payment vouchers;
• tax deduction vouchers.

Check finalization obligations

Especially for individuals:

• with multiple income sources;
• self-employed;
• receiving income from multiple organizations.

Prepare explanation documents

Retain:

• service contracts;
• payment vouchers;
• bank statements;
• invoices;
• tax deduction certificates;
• documents proving tax exemptions, reductions, or non-taxable income.

Fulfill all tax obligations

If any deficiencies are found, taxpayers should proactively file supplementary declarations and pay all arising taxes as stipulated to mitigate risks of penalties.

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