Introduction
In our work supporting foreign-invested (FDI) companies in Vietnam on accounting and recruitment, we sometimes hear from local Chief Accountants (hereafter “CA”) or accounting staff: “I’m not sure how to handle the instructions I’m getting from my foreign supervisor.”
When we look closer, most of these cases involve no bad intent on the foreign manager’s side. In their home country, the very same instruction would be ordinary, and they think of it as “just a small request.” But when applied against Vietnam’s accounting and tax framework, the same instruction can put the local accountant in front of real tax risk or compliance risk.
An unconscious instruction can push the local accountant into a corner, raise the risk of denial during a tax inspection, and become a professional and psychological burden for the CA personally. In this article, we organize five typical “NG instructions” — instructions foreign managers in Vietnam unconsciously give that tend to backfire — together with the background and the way to course-correct each one. Our hope is that it offers a useful prompt to revisit how instructions are given inside your own company.
1. Why an “Ordinary” Instruction at Headquarters Becomes a Problem in Vietnam
A core reason these instructions go wrong is that Vietnam’s accounting and tax framework rests on different default assumptions from those of most home-country headquarters.
In many home countries, telling the accountant verbally to “just book this as an expense” is enough — the accountant uses their own judgment to complete the treatment, and the documentation around it is handled with some flexibility. Even where tax authorities are rigorous, the depth of paperwork required and the strictness of approach to supporting documents may not be at the level Vietnam expects. Home-country accountants are also relatively used to “just getting it done now and tidying up later.”
Vietnam works differently. For an expense to be deductible for corporate income tax (CIT), or for input VAT to be creditable, the documentation requirements are strict: a valid VAT invoice (Hóa đơn GTGT), a contract, and proof of payment all need to be in place. On top of this, the Chief Accountant is institutionally placed in a position of responsibility for the company’s accounting records and tax filings. “I just did what I was told” is often not enough to protect the individual.
In other words, what a foreign manager treats as “a small administrative request” can, on the local accountant’s side, be “a treatment that directly affects my own professional responsibility.” If this gap in default assumptions is left unaddressed, the local accounting function quietly burns out, and the strongest accountants are the first to step away.
2. Five NG Instructions Foreign Managers Tend to Give Unconsciously
From many conversations with accountants at foreign-invested entities in Vietnam, we have noticed that the instructions foreign managers give without thinking tend to fall into a few common patterns.
NG Instruction 1: “Just book it as an expense”
The most common case is an instruction to “just expense it” or “put it through as a cost” without verifying whether the expenditure is actually deductible or whether the supporting documents are in place.
In Vietnam, corporate income tax deductibility requires a VAT invoice, a contract, and proof of payment to be present and consistent. Expenditures that do not meet these requirements can be denied during a tax inspection, with additional tax and late-payment interest assessed. Assuming “if accounting booked it as a cost, it must be fine” is, in Vietnam, a genuinely risky assumption.
This applies especially to entertainment expenses, consulting fees, expenditures involving overseas remittances, and related-party transactions — all areas the tax authorities look at closely. When a “just expense it” instruction lands on the accountant, they are left in the position of “I processed it as instructed, but I cannot explain it in a tax inspection.”
NG Instruction 2: “We’ll get the invoice later — process it now”
In many home countries, it is normal to perform a transaction first and receive the invoice afterward. The accrual booking carries it across month-end, and tax treatment is generally not greatly affected.
In Vietnam, there are rules around when a VAT invoice should be issued, and the appropriate timing depends on the nature of the goods or services and the contract terms. Invoices issued after the fact — particularly those issued after a tax period has closed — carry real risk of being denied by the tax authorities as the basis for VAT credit or CIT deductibility.
Accountants run their daily work with these rules in mind. When an instruction lands to “process it now, the invoice will come later,” they read it as “if I follow the instruction, I am the one carrying the denial risk later.”
NG Instruction 3: “Adjust the local books to match headquarters’ format”
For consolidation or headquarters reporting purposes, managers sometimes ask: “Please adjust the local books so the numbers line up with what HQ sees.” From the manager’s perspective, the request is simple — different numbers in two places are inconvenient, so make them match.
But Vietnam’s statutory books are required to be maintained under Vietnamese Accounting Standards (VAS). They are not something that can be rewritten to match a headquarters format. Headquarters reporting should be produced separately, by reclassifying and adjusting from the VAS-based statutory books — not by altering the statutory books themselves. Modifying the statutory books to match the headquarters format is simply not permitted under Vietnamese accounting rules.
From the accountant’s perspective, “rewrite the Vietnamese statutory books so HQ’s numbers tie” is effectively a request to break the law.
NG Instruction 4: “I paid on my personal card — just expense it”
When foreign managers cover business travel, urgent purchases, or client entertainment on their personal credit card or in cash, they often ask the local accountant to “expense it later.” In many home countries, this kind of expense reimbursement is routine.
Reimbursement is also possible in Vietnam, but for the expense to be CIT-deductible and the VAT to be creditable, the rule is generally that a VAT invoice issued by the vendor in the company’s name is required. A restaurant receipt in an individual’s name, or an English-language invoice issued overseas, may not on its own satisfy Vietnam’s documentation requirements.
Spending during overseas business trips, payments for overseas services, and cash receipts with no formal VAT invoice are areas of particularly high denial risk in a tax inspection. Before casually saying “I paid on my card, just expense it,” it is worth building the habit of first checking with the accountant whether Vietnam’s documentation requirements will be met.
NG Instruction 5: “I told you verbally — no need to put it in writing”
In many home-office cultures, instructions and informal agreements are passed verbally. The mindset “we don’t need to write it down — we can confirm later if it ever comes up” is widespread.
For the Vietnamese accountant, processing on verbal instruction alone is a major source of anxiety. If, later, a tax inspection or internal audit asks “why was this treatment chosen?” — or a new manager arrives and asks the same — saying “my foreign supervisor told me to” without supporting written evidence may not provide enough protection.
For exceptional accounting treatments, grey-zone tax judgments, and special agreements with headquarters in particular, building the habit of retaining a written record by email or formal approval is what protects both the accountant and the company.
3. Why Managers Give These Instructions “Unconsciously”
These instructions almost never come from bad intent. In most cases, the background looks like this.
Home-country accounting habits are deeply ingrained
Practices that are completely ordinary back home may not be permitted under Vietnamese rules, or carry significantly higher risk. There are limited opportunities for managers to systematically learn where the gaps are.
Accountants are positioned as “the people who process things”
Without consciously registering that the local accountant carries personal responsibility, managers fall back on the home-country reflex of “please handle this,” and the same approach continues abroad.
Language gap
When instructions are given to Vietnamese accounting staff through English or via an interpreter, nuance often does not fully transfer, and the accountant is left with no realistic option other than to “just process something.”
None of these are individual failings — they are structurally likely situations. That is precisely why it helps for managers to approach their own instructions with the working assumption that “I may also be doing this unconsciously” and review how they give instructions on that basis.
4. What Managers Can Be Mindful Of
To reduce unconscious NG instructions, here are some practical points managers can adopt.
Separate “how it works at headquarters” from “how it works in Vietnam”
Before issuing an instruction, build the habit of consciously distinguishing “is this an instruction I’m giving based on my home-country sense?” versus “how would this actually be treated under Vietnamese rules?” For points where the answer is unclear, asking the accountant “how should this be handled in Vietnam?” goes a long way toward reducing unintentional risk instructions.
Put exceptional and grey-zone treatments in writing
For exceptional accounting treatments, grey-zone tax judgments, and special agreements with headquarters, make it a habit to retain the decision in writing — email, formal approval, or an internal memo. This protects the accountant and at the same time strengthens the company’s ability to explain itself in future tax inspections, audits, and handovers.
Do not place grey-zone judgments on the accountant alone
For areas where there is room for judgment — deductibility, VAT credit eligibility, related-party transactions, the timing of revenue or expense recognition — we recommend examining the issue together with an accounting firm or tax specialist and retaining the outcome as a company decision on record. Pushing the call onto the individual accountant turns it into a professional risk for them, which in turn affects retention.
Reduce “just” and “somehow”
Phrases like “just expense it” or “somehow process this” are among the most difficult instructions for an accountant to receive. Before giving an instruction, taking a moment to clarify “how specifically should this be processed?” “are the supporting documents in place?” “is there a tax risk to be aware of?” can substantially reduce the burden and risk carried by the accounting team.
Build a relationship where you can ask the accountant “why”
Maintaining regular communication with the accountant — where both “why are we doing it this way?” and “why is this instruction difficult?” can be discussed openly — is, in our experience, the single most effective way to reduce unconscious NG instructions. When asked, accountants will typically explain in detail how a given treatment is viewed under Vietnamese rules.
Closing Thoughts
The NG instructions foreign managers give to accounting unconsciously are not a matter of bad intent. They are a structural issue rooted in the fact that home-country accounting habits are deeply ingrained. Under Vietnamese rules, however, the same instructions can translate directly into tax risk, compliance risk, and professional risk for the local accountant.
The strongest accounting talent is the most sensitive to these risks. When unconscious NG instructions accumulate, accountants quietly burn out, and some begin to think about moving on.
Separate “how it works at home” from “how it works in Vietnam.” Put exceptional treatments in writing. Do not place grey-zone judgments on the accountant alone. Reduce “just” and “somehow” from your instruction vocabulary. Build a relationship where you can ask the accountant “why.”
These connect directly not only to retaining strong accounting talent but also to protecting the company itself from tax and compliance risk. We hope this article offers a useful prompt to revisit how instructions are given inside your own company.
FAQ
Q1. Do foreign managers need to study Vietnamese accounting and tax systematically?
A. We do not think every detail needs to be memorized.
That said, simply understanding a few foundational premises — “documentation requirements for deductibility and VAT credit in Vietnam are strict,” “VAS-based statutory books cannot be rewritten to match a headquarters format,” “the local accountant carries personal responsibility for the accounting records” — already reduces unconscious NG instructions substantially.
The detailed judgments can be entrusted to the accountant and to external specialists. The important habit for managers is to consciously ask: “how would my instruction actually be treated under Vietnamese rules?”
Q2. If the accountant says “I cannot do this,” how should we receive that?
A. The first step is to listen carefully to why they cannot.
When an accountant pushes back, there is almost always a concrete concern behind it — tax risk, compliance risk, missing documentation. Reading the response as “they’re being difficult” or “they won’t be flexible” closes off the early-warning signal. Receiving it instead as a real risk warning is what ends up protecting the company.
From there, where useful, engage an accounting firm or tax specialist to organize “how the company should decide on this.”
Q3. When headquarters’ requirements and the local accountant’s position conflict, which should take priority?
A. Statutory books must follow Vietnamese Accounting Standards (VAS), so rewriting the local statutory books to match a headquarters requirement is not appropriate.
In practice, the workable approach is to maintain VAS-based statutory books and, separately, produce a “management reporting pack” reclassified and adjusted to headquarters’ format. This satisfies both sides. Where the right way forward is unclear, engaging an accounting firm or auditor to design a setup acceptable to both headquarters and the local team is the constructive route.
