For importing businesses, the reduction of paper-based documentation is accompanied by higher expectations for the accuracy, consistency, and traceability of electronic data. To minimize potential supply chain disruptions and reduce the risk of late payment charges, businesses should review and strengthen the following five operational areas.

1. Strengthen Electronic Document Management Instead of Focusing Solely on Paper Documents

One of the notable changes introduced by Circular No. 86 is that customs authorities are permitted to retrieve eligible tax exemption, reduction, and refund documents that are already available through the National Single Window, the ASEAN Single Window, or other specialized government information systems. As a result, businesses are generally no longer required to resubmit paper documents or duplicate scanned copies, provided that the relevant electronic identification information is supplied.

This approach reduces duplicate document submissions while placing greater emphasis on maintaining accurate document identifiers from the earliest stages of contract preparation and import documentation.

Recommendations

2. Manage the Five-Business-Day Deadline for Post-Clearance Tax Adjustments

Circular No. 86 clarifies the deadline for paying additional taxes arising after goods have already been released through customs. Taxpayers are required to pay the additional tax within five business days from certain triggering events, including:

These requirements highlight the importance of effective coordination among relevant departments to ensure information is communicated promptly and post-clearance tax obligations are fulfilled within the prescribed timeframe.

Recommendations

3. Avoid the "Last-Minute Payment" Risk When Paying Customs Duties Electronically

Circular No. 86 clarifies that, for electronic tax payments, the official payment date is the date on which funds are successfully debited from the taxpayer's account and the transaction is confirmed by the payment service provider or intermediary payment service provider. Simply initiating a payment instruction does not mean the tax obligation has been fulfilled.

In practice, submitting electronic tax payments close to the statutory deadline increases the likelihood of technical issues or delays in transaction confirmation.

Recommendations

4. Review Tax Declarations Following Import VAT Refunds

Data sharing between Customs and domestic tax authorities continues to expand, particularly in the administration of overpaid import Value-Added Tax (VAT). When Customs issues a decision approving an import VAT refund, the relevant information may be updated within the tax administration system and shared with the domestic tax authority.

If a business has already claimed the same VAT amount as an input VAT credit with the domestic tax authority but fails to adjust its tax declaration after receiving the Customs refund decision, it may be subject to tax reassessment and administrative penalties for claiming tax benefits that are no longer applicable under the regulations.

Recommendations

5. Strengthen Cross-Functional Internal Coordination

The changes introduced under Circular No. 86 extend beyond customs declaration procedures and affect multiple business functions, including procurement, accounting, finance, and contract management.

In many organizations, purchase contracts, customs value adjustments, payment records, and tax obligations are managed by different departments. As processing timelines become shorter and government systems become increasingly interconnected, ineffective internal coordination can increase the risk of delayed supplementary declarations or late tax payments.

Recommendations

Businesses may consider strengthening internal coordination through the following operational controls:

Conclusion

Circular No. 86/2026/TT-BTC not only updates the regulatory framework governing tax administration for exported and imported goods but also reflects a broader transition toward digital data management and greater integration across government agencies.

As tax administration becomes increasingly data-driven, understanding regulatory requirements alone is no longer sufficient. Businesses should also establish well-defined internal processes, maintain consistent data management practices, and strengthen coordination across departments. These measures can help reduce compliance risks, minimize unexpected costs, and support more stable import operations.

With more than 24 years of hands-on experience in customs services and integrated logistics, Vantage Logistics works alongside businesses by providing practical support throughout the customs clearance process, including:

Circular No. 86 is now in effect. Is your import compliance process fully prepared? Contact Vantage Logistics today to discuss your business requirements with our customs and logistics specialists.