Freezing tax debt during dissolution

Yes. A taxpayer that has sent the dissolution resolution and has been recorded by the business registration authority as “carrying out dissolution procedures” on the national information system, but has not yet completed dissolution, falls within the cases where tax debt may be frozen. The head of the tax authority decides on the freeze.

• Other cases are also eligible for a freeze: no longer operating at the registered address; the registration certificate has been revoked.

Legal basis: Points b, d and dd of Clause 1 and Clause 2, Article 20 of the Law on Tax Administration 108/2025/QH15; Clause 1, Article 34 of Decree 252/2026/NĐ-CP. Further reading: /kien-thuc/giai-the-cong-ty-con-no-thue/.

It must still be paid. A freeze only means the enterprise is temporarily not charged late-payment interest during the freeze period; when the freeze decision ceases to be effective, the tax authority calculates late-payment interest in full from the tax payment deadline. Freezing debt is different from writing off debt.

• During the freeze, the tax authority continues to monitor and urge collection when the taxpayer has the ability to pay.

Legal basis: Clauses 3 and 4, Article 20 of Law 108/2025/QH15; Clause 5, Article 34 of Decree 252/2026/NĐ-CP. Further reading: /kien-thuc/giai-the-cong-ty-con-no-thue/.

In cases of dissolution, abandonment of the address or revocation of the registration certificate, the amount frozen is the total tax debt at the time the freeze begins. The freeze period runs from the date of the freeze decision until the date the decision to terminate that decision takes effect.

• If the amount of debt changes after the freeze, the tax authority issues a decision to adjust it.

Legal basis: Point a of Clause 3, and Points a and c of Clause 4, Article 34 of Decree 252/2026/NĐ-CP.

No, if the parent enterprise is still operating. The tax authority does not freeze debt under the cases of dissolution, abandonment of the address or revocation of the registration certificate for a branch, representative office or business location of an enterprise or organization that is still operating.

• The parent enterprise is responsible for fulfilling the tax obligations of its dependent units (Point đ, Clause 1, Article 17 of Law 108/2025/QH15).

Legal basis: Clause 1, Article 34 of Decree 252/2026/NĐ-CP. Further reading: /hoi-dap/ (question b21). Thái Tín supports the procedures for closing branches and representative offices — contact us to have your dossier reviewed.

A freeze decision ends when the taxpayer has fulfilled its tax payment obligation, when it resumes business operations, when the debt becomes eligible for write-off, or when the owner of the sole proprietorship or the single-member limited liability company establishes another enterprise. After that, late-payment interest is calculated in full.

• Fulfilling the obligation is the most proactive way to close the file.

Legal basis: Points a, b, d and e of Clause 6, Article 34 of Decree 252/2026/NĐ-CP; Clause 4, Article 20 of Law 108/2025/QH15.

Yes. A taxpayer whose enterprise registration certificate has been revoked by a competent authority falls within the cases where tax debt may be frozen. The amount frozen is the total tax debt at the time the freeze begins; during the freeze, late-payment interest is temporarily not charged.

• A freeze is not a write-off: when the freeze decision ceases to be effective, late-payment interest is calculated in full from the payment deadline.
• This case does not apply to a branch, representative office or business location while the enterprise is still operating.

Legal basis: Point đ of Clause 1 and Clause 4, Article 20 of the Law on Tax Administration 108/2025/QH15; Clause 1, Point a of Clause 3 and Point a of Clause 4, Article 34 of Decree 252/2026/NĐ-CP. Further reading: /kien-thuc/giai-the-theo-quyet-dinh-thu-hoi-giay-chung-nhan/.