NON-AGRICULTURAL LAND USE TAX: DATA BOTTLENECKS AND THE CHALLENGES OF REAL ESTATE MANAGEMENT

1. Land Data Has Yet to Keep Pace with Actual Changes

In late October 2026, the tax authorities called on local authorities to step up efforts to address outstanding issues in the administration of non-agricultural land use tax. The reported problems mainly involved inaccurate taxpayer information, outdated land parcel records, and tax payments that had been made but were still recorded as outstanding in the system.

In Hanoi, one reported case involved a family that had divided a land parcel into three portions for their children, while the 2026 tax notice continued to reflect the previous information. According to the report, the land registration procedures for recording the changes had not yet been completed at that time. Therefore, the legal records and tax data need to be cross-checked to establish the full reasons for the discrepancy.

In Soc Son, a resident reported receiving tax notices for four land parcels, although the family stated that it owned only one. This remains a case reported by a resident and should not be treated as an independently verified finding regarding the accuracy of cadastral data.

In addition, the tax authorities have called for a review and reconciliation of outstanding tax liabilities, payments received, and accounting records, with a view to addressing cases in which payments have not been updated or have been incorrectly recorded as unpaid.

These situations indicate that the problem is not limited to tax declaration procedures. It also concerns the ability to update, synchronize, and reconcile data across different management systems.

2. Review Progress and Outstanding Issues

According to published figures, a total of 3,372,799 tax returns were subject to review, of which 95.57% had been reviewed. This represents approximately 3.22 million returns, calculated based on the reported completion rate.

On October 29, 2026, the General Department of Taxation issued Official Letter No. 8171/CT-NVT on strengthening the administration of non-agricultural land use tax. The document called for continued data standardization, the correction of discrepancies, and the resolution of taxpayers' complaints and feedback.

However, it is important to distinguish between the proportion of returns reviewed, the proportion verified as accurate, and the proportion of reported issues fully resolved. The available sources do not provide comprehensive figures for these three indicators.

Therefore, the 95.57% figure reflects progress in carrying out the review process, but it is not sufficient to conclude that all reviewed records have been standardized or are free of discrepancies.

3. Tax Administration Is Shifting Its Focus Towards Data Standardization

One notable change in the direction of tax administration is the move towards reducing paperwork and making greater use of existing data held by government agencies.

According to published information on Law No. 108/2025/QH15 on Tax Administration, Decree No. 252/2026/ND-CP, and Circular No. 89/2026/TT-BTC, taxpayers are not required to obtain confirmation from relevant authorities on tax declarations or resubmit documents already held by government agencies, provided that such information is eligible for data connection and retrieval. The exemption from submitting tax declarations applies where the tax authority has established the necessary data connections and possesses complete land information in accordance with applicable regulations.

At the same time, Official Letter No. 8171/CT-NVT calls for closer coordination and the review of taxpayer information, land parcel records, and the status of financial obligations.

This indicates that the effectiveness of administrative reform increasingly depends on the quality of underlying data. When information on taxpayers, land areas, legal status, and payment histories is inconsistent across systems, reducing paperwork does not necessarily translate into shorter processing times.

4. Implications for Real Estate Development Activities

From a real estate developer's perspective, these shortcomings highlight the need to manage land records throughout the entire asset lifecycle.

First, control legal documentation and changes to land parcels. Activities such as land subdivision, parcel consolidation, transfers, and changes to land user information need to be monitored and reconciled with tax administration data. Businesses should establish a land-record management system for each parcel, covering legal information, transaction and change history, and the status of financial obligations.

Second, manage costs and financial obligations. Non-agricultural land use tax must be distinguished from land use fees, land rental payments, and other financial obligations arising during project development. Accurate classification enables businesses to monitor amounts payable, prepare budgets, and control operating costs.

Third, mitigate risks in transactions and handovers. Inconsistent data may increase the time required to verify documentation, reconcile payment records, or resolve financial obligations that have not been accurately recorded. Therefore, legal and financial status checks should be conducted before transactions, transfers, or asset handovers.

The available sources do not provide quantitative data on the impact of these issues on total investment costs, project timelines, or real estate absorption rates. Accordingly, there is currently insufficient evidence to conclude that these shortcomings directly increase costs or affect market prices.

5. Key Management Considerations

A review of the published information highlights five issues worth noting:

• A high review rate does not necessarily mean accurate data: Further monitoring is needed to determine the proportion of discrepancies corrected and the number of reported issues fully resolved.

• Changes in legal status must be updated promptly: Cases involving changes to land status or ownership transfers that have not been reflected in management records highlight the need for closer reconciliation between legal documentation and tax administration systems.

• Digital transformation depends on data quality: Electronic systems can only deliver their intended benefits when input data is consistent and clear procedures are in place to address discrepancies.

• Reducing paperwork requires stronger data connectivity: As government agencies increasingly rely on existing information, data accuracy and consistency become essential conditions for reducing administrative procedures.

• Management effectiveness should be measured by resolution outcomes: In addition to the number of records reviewed, attention should be paid to processing times, unresolved cases, and the accurate recording of payments already made.

6. Data Is Becoming an Integral Part of Real Estate Management Capabilities

In the long term, standardizing land data and financial obligation records is not merely a requirement for government agencies; it is also an internal management priority for real estate businesses.

Developers need to move away from maintaining fragmented records towards integrated data management that enables cross-checking of legal, financial, and operational information. An effective asset management system should track land parcel details, land users, changes over time, and the status of financial obligations.

For investors, the quality of documentation and the ability to verify information are also important factors when assessing an asset. However, any assessment of broader market impacts must be based on actual data regarding costs, processing times, and the frequency of administrative issues, rather than extrapolations from isolated cases.

Conclusion

The shortcomings in non-agricultural land use tax administration demonstrate that data standardization remains an important task, even though the reported rate of reviewed tax returns has reached 95.57%.

For real estate businesses, the key lesson goes beyond fulfilling financial obligations. It also lies in the ability to manage legal documentation, land changes, and payment histories in an integrated manner. Over the long term, data quality is one of the essential foundations for helping businesses control risks and improve asset management efficiency.