NEWSLETTER OCTOBER 2025
Circular 99/2025/TT-BTC of the Ministry of Finance on the accounting regime, effective from 1 January 2026
On 27 October 2025, the Minister of Finance issued Circular No. 99/2025/TT-BTC (“Circular 99”) providing guidance on the corporate accounting regime, replacing Circular No. 200/2014/TT-BTC dated 22 December 2014 of the Ministry of Finance on the corporate accounting regime and its amending and supplementing circulars; as well as Circular No. 195/2012/TT-BTC dated 15 November 2012 providing accounting guidance for project owners. This Circular applies to all enterprises operating in economic sectors in Vietnam, including parent companies, corporations, and dependent units, to ensure compliance with legal provisions on accounting and management.
Some notable new points of Circular 99 compared with Circular 200:
1.1 Changes to accounting accounts
- Renaming certain accounts:
Account 155 – Products (formerly “Finished goods”);
Account 242 – Deferred expenses (formerly “Prepaid expenses”);
Account 419 – Treasury shares repurchased (formerly “Treasury shares”);
…
- Adding Account 215 – Biological assets. Circular 99 also provides detailed sub-accounts such as 2151 (Periodic livestock), 21511/21512 (immature/mature stage), 21521/21522 (original cost/accumulated depreciation), and accounts 2152–2153 for crops and one-time products…
- Separating Account 821 for Global Minimum Tax: In addition to 8211 (corporate income tax) and 8212 (deferred corporate income tax), Circular 99 adds detailed levels under account 8211:
82111 – Current corporate income tax expense under the Law on CIT; and
82112 – Additional corporate income tax expense under the 15% Global Minimum Tax regulations.
1.2 Changes to the Financial Statements
The name “Balance Sheet” is changed to “Statement of Financial Position.”
New items on the Statement of Financial Position (and changes to certain item codes):
- Biological assets (Current – code 150; Non-current – code 230), with details such as: Periodic livestock, Seasonal crops or one-time harvest crops, Provision for impairment of biological assets
- Provision for held-to-maturity investments – short term (code 124), Other short-term investments (code 125), Provision for impairment of other short-term investments (code 126)
- Dividends and profits payable (code 313)
- Long-term taxes and amounts payable to the State (code 333), etc.
Some items are removed from the Statement of Financial Position: Loans receivable, Capital construction investment sources, budgetary funds and other funds…
A new item is added to the Statement of Profit or Loss: “Gain/loss from the sale or disposal of investment property” (code 21).
1.3 New provisions on the functional currency in accounting
Under Circular 200, enterprises are only allowed to use VND or a foreign currency if approved.
Articles 4, 5, and 6 of Circular 99 clearly regulate how to determine, change, and convert the functional currency in accounting, specifically:
- When an enterprise is permitted to use a foreign currency as its accounting currency, it must meet conditions regarding revenue, expenses, and capital mobilization.
- If changing the accounting currency (e.g., from USD to VND), the change must be made at the beginning of the fiscal year and must use the average transfer exchange rate of the bank with which the enterprise frequently conducts transactions.
- Financial statements must still be submitted in Vietnamese Dong, even when accounting records are maintained in a foreign currency.
1.4 Circular 99 provides detailed regulations on the classification of current and non-current assets, and current and non-current liabilities in the Statement of Financial Position.
1.5 Circular 99 introduces new regulations on converting financial statements prepared in a foreign currency into Vietnamese Dong. Enterprises must translate the financial statement items according to the following principles:
- Assets and liabilities: using the average transfer exchange rate quoted by the commercial bank with which the enterprise most frequently transacts.
- Equity (owner’s capital contributions, capital surplus, other capital, bond conversion options): using the actual exchange rate on the date of capital contribution.
- Revaluation differences of assets: using actual transaction exchange rate on the date of revaluation.
- Items in the Statement of Profit or Loss and the Statement of Cash Flows: using the actual transaction exchange rate at the time the transactions occur. If the average exchange rate for the accounting period approximates the actual transaction exchange rate (differences not exceeding the permitted band), the enterprise may apply the average exchange rate for the period (if chosen).
1.6 Some accounting principles
- When crediting Accounts Receivable or debiting Accounts Payable, accountants are allowed to choose between the actual transaction exchange rate or the exchange rate recorded in the books.
- Principle for revaluation of foreign currency-denominated monetary items: Revalue the balances of all foreign currency-denominated monetary items according to the average transfer buying–selling exchange rate of the commercial bank where the enterprise regularly transacts, at the end of the accounting period. (For the balance of foreign currency-denominated demand deposits, revaluation must be done according to the average transfer buying–selling exchange rate of the commercial bank where the enterprise holds the deposit account. Revaluation is not required for foreign currency receivables that have been provisioned for doubtful debts.)
- Addition of principle for capitalizing unfinished construction costs: Only those costs directly related to the investment in the construction of fixed assets (FA), investment properties (IP) (i.e., necessary and unavoidable costs when carrying out construction investment activities), and the construction process of unfinished assets that are not unusually delayed or suspended due to slow progress compared to the projected construction schedule, can be capitalized into the value of fixed assets or investment properties. Exchange rate differences should not be capitalized into the value of unfinished assets.



