4 Nov 2026 · Vietnam VI

Citizenship · Capital · Global Mobility

The Legation Times

Vietnam has set no date to receive foreign account data under CRS

Edward Nguyen Edward Nguyen
A hand holds the reverse of a Vietnamese 100,000 dong banknote, which shows the Khue Van Pavilion, in front of the same pavilion and trees at the Temple of Literature in Hanoi

OECD lists read on 15 October 2026 show no automatic exchange that sends Vietnam yearly reports on residents' accounts in Singapore, Switzerland or Portugal; requests about a named person remain possible.

The OECD tables read on 15 October 2026 list no relationship under which Singapore, Switzerland or Portugal would send Vietnam yearly reports on its tax residents’ accounts. Vietnam is listed among developing countries not asked to commit and that have not yet set a date for first exchanges under the Common Reporting Standard. Information about a named person can still be requested under tax treaties.

How the standard reaches a home country

Under the Common Reporting Standard, banks report accounts held by non-residents to their own tax authority, which exchanges the data each year, automatically, with the authority of the account holder’s country of residence.

The OECD describes a three-step process in which both jurisdictions must join the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, sign the multilateral CRS agreement between tax authorities and file notifications under it.

A relationship takes effect only if both have the Convention in effect, have filed all of those notifications and have listed each other, according to the OECD’s questions and answers on exchange relationships.

The OECD status of commitments, last updated on 30 September 2026, lists Portugal and Greece among jurisdictions undertaking first exchanges in 2017, and Singapore, Switzerland and Hong Kong among those undertaking first exchanges by 2018. The United States is in none of those groups; the list notes that it has exchanged automatically under FATCA from 2015.

Where Vietnam stands on the OECD lists

Vietnam joined the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes in 2020. The multilateral tax assistance convention, which Vietnam signed on 22 March 2023, has been in force for it since 1 December 2023, according to the OECD status table of 1 September 2026.

Joining the convention is the first of those three steps. Vietnam does not appear on the OECD list of signatories to the agreement that puts CRS exchanges into effect, which carries a status date of 13 March 2025.

The commitments list of 30 September 2026 places Vietnam among the “developing countries not asked to commit and that have not yet set a date for the first year of exchanges”. The OECD table of activated relationships, which carries no date and was read on 15 October 2026, lists none with Vietnam as sender or receiver.

The Global Forum’s Asia report of June 2026 records, with data as of 31 December 2025, “CRS commitment: No” for Vietnam. It places Vietnam with Cambodia, the Philippines, Sri Lanka and Uzbekistan among Asian members not yet committed to start by a specific date.

What can still travel: a request about one person

Exchange on request works without the CRS relationship. Article 27 of the Singapore–Vietnam tax treaty, as amended by a protocol in force since 11 January 2013, covers information that is “foreseeably relevant” to either country’s taxes. A state may not decline to supply it “solely because the information is held by a bank”.

This means one tax authority can ask the other about a specific taxpayer. The treaty text sets up no routine annual report of accounts.

According to an English-language government portal report of 23 March 2023, the multilateral convention enables jurisdictions to engage in mutual assistance including “exchange of information on request”. The OECD status table lists Switzerland, in force since 1 January 2017, and Portugal, since 1 March 2015, as parties.

A Global Forum peer review published on 10 November 2025 rated Vietnam “Non-Compliant” with the on-request standard. It found that the tax authorities’ broad access powers for domestic tax purposes “cannot be fully used for exchange of information purposes”.

According to a government portal report of 29 May 2026, Deputy Prime Minister Nguyen Van Thang signed Decision 948/QĐ-TTg, a national action plan on exchange of information on request.

FATCA and the United States

Vietnam’s agreement with the United States under FATCA has been in force since 7 July 2016, according to the US Treasury. Article 2 of the agreement text requires Vietnam to obtain information on “U.S. Reportable Accounts” and to exchange it with the United States each year.

The text defines no category of Vietnamese reportable accounts. This indicates that the automatic reporting runs from Vietnam to the United States, and that the text provides for no report to Vietnam on Vietnamese residents’ accounts in the United States.

Vietnam’s domestic law on information exchange

The Law on Tax Administration No. 108/2025/QH15 replaced Law 38/2019 on 1 July 2026. Article 30 gives the tax authority the task of exchanging taxpayer information with foreign tax authorities under treaties, and of collecting information to the Global Forum’s standards.

Decree 252/2026/NĐ-CP, in force the same day, requires credit institutions to supply information “under the financial account reporting standard” on persons who are not tax resident in Vietnam. Article 63 provides for automatic exchange of such reports under treaties or agreements Vietnam is party to or has signed.

This means the domestic basis for reporting non-residents’ accounts held in Vietnam now exists. The inbound flow on Vietnamese residents’ accounts abroad still depends on an activated relationship, and the OECD table read on 15 October 2026 lists none for Vietnam.

What this article has not established

The OECD signatory list read on 15 October 2026 carries a status date of 13 March 2025, so a later signature by Vietnam cannot be ruled out from it.

The commitments list of 30 September 2026 shows no date for Vietnam, and the OECD table of activated relationships, which carries no date, lists none.

No Vietnamese official statement about joining CRS was found in searches of the Ministry of Finance, the tax department and the government portal on 15 October 2026.

The implementing circular for Decree 252, Circular 89/2026/TT-BTC, was not read.

The full text of Decision 948/QĐ-TTg was not read; only the government portal’s summary was.

Whether a working on-request channel exists between the United States and Vietnam was not established.

Who counts as a Vietnamese tax resident is covered in an explainer on tax residence.

The rules on moving money abroad for settlement are covered in a separate article.

The Legation Times writes its content from published documents; nothing here is legal, tax or investment advice. Spotted an error? Send a correction request; for content rights, send a takedown request.

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