Determining the correct criteria for consolidating financial statements that are no older than 15 months is particularly important for newly established businesses at the end of 2025, especially in the current context. Circular 99/2025/TT-BTC Officially effective from January 1, 2026. Many businesses mistakenly believe that as long as the first accounting period is less than 3 months, they can consolidate financial statements to the following year. However, in reality, many legal issues arise related to the transition to a new accounting system. This article will analyze in detail the conditions for consolidating financial statements no longer than 15 months according to the 2015 Accounting Law. Official Document 66/QLKT-DN and Decree 20/2026/ND-CPThis helps accountants and business owners understand when consolidation is permissible and when separate financial statements are required, while also maximizing the benefits of corporate income tax exemption during the first three years of operation.
Legal framework for the first accounting period under the Accounting Law 2015
Before considering the conditions for consolidating financial statements for no more than 15 months, we need to return to the core principles of accounting periods as stipulated in the 2015 Accounting Law. This is the foundation upon which all subsequent guiding circulars must adhere.
According to regulations, an accounting period is understood as the time from the time accounting entries are recorded to the time the books are closed for the preparation of financial statements. For a normally operating business, the accounting year is 12 full months according to the calendar year, starting from January 1st to December 31st. However, for newly established entities, the 2015 Accounting Law provides specific guidance in Article 12 as follows:
- The first accounting period for a newly established business runs from the date the Business Registration Certificate is issued until the last day of the accounting year (December 31st).
- Businesses with unique business cycles may register for a different accounting year, but must ensure it is at least 12 months long and notify the tax authorities.
The problem arises when a business is established too late in the year, for example, on December 10th. If it is mandatory to prepare financial statements for only 21 days of operation, the business will incur unnecessary costs. Therefore, a flexible mechanism for consolidating financial statements for no more than 15 months was introduced to solve this problem.
Businesses should seek consultation. accounting services from the accounting services company Reputable and experienced professionals with expertise in accounting and tax support can ensure legal compliance and protect the company's interests.
Understanding the practical application of the condition of consolidating financial statements no older than 15 months.
According to Clause 4, Article 12 of the 2015 Accounting Law, a business is allowed to consolidate accounting periods if it meets specific criteria. The key point here is that the first accounting period must not exceed three consecutive months.
If the period meets the criterion of being less than 3 months, the business is allowed to combine this period with the following accounting year to form a single period. However, a crucial rule that accountants must remember is that the combined financial statements must not exceed 15 months. This means that if a business is established in October 2025 (first period of 3 months), it can combine it with the 12 months of 2026, creating a single accounting period of exactly 15 months. If established in September 2025 (first period of 4 months), the business is required to submit separate financial statements for 2025 because combining them would violate the 15-month rule (resulting in a total of 16 months).
However, during the transition period between the old and new accounting systems in 2026, the application of the condition that consolidated financial statements should not exceed 15 months faced obstacles from the latest guiding circulars of the Ministry of Finance.
Circular 99/2025/TT-BTC applies to businesses established at the end of 2025.
Circular 99/2025/TT-BTC, guiding the accounting regime for enterprises, was issued with the goal of modernizing the financial management system. According to Article 31 of this Circular, its effective date is January 1, 2026. This creates a technical barrier that prevents many businesses, even those wishing to, from consolidating financial statements for no more than 15 months.
Official Document 66/QLKT-DN
On January 15, 2026, the Accounting and Auditing Supervision Department issued Official Letter 66/QLKT-DN to officially respond to the issue of consolidating reports. According to the letter, although the company's establishment between December 10, 2025 and December 31, 2025 is less than three months, there is no basis to apply Circular 99 before January 1, 2026.
Circular 99/2025/TT-BTC only applies to fiscal years beginning on or after January 1, 2026. Businesses cannot account for transactions in December 2025 according to Circular 99. If a business combines the 2025 period with the 2026 period, that report will become a inconsistent entity in terms of accounting system (December 2025 according to the old system, 2026 according to the new system).
Therefore, although the Accounting Law allows it, due to the difference in regulations between the two years, businesses established in December 2025 are not allowed to apply the condition of consolidating financial statements for no more than 15 months. In this case, the best option is for the business to proactively take action. hire an accountant to prepare financial statements. To ensure the consistency of accounting data before transitioning to Circular 99.
The implications of prohibiting mergers for the regulatory body.
Requiring separate submissions of the 2025 report helps the Tax and Finance authorities finalize the old data before entering the new accounting era. This avoids confusion in applying new accounting accounts or asset valuation methods that may change between the two regimes. However, this is a necessary requirement to ensure transparency when considering the conditions for consolidating financial statements for no more than 15 months on an overall basis.
Cases where businesses apply Circular 133
Not all businesses are unable to consolidate their reports in 2026. A significant segment can still flexibly apply the condition of consolidating financial statements for no more than 15 months, namely businesses that apply the accounting regime according to Circular 133/2016/TT-BTC (for small and medium-sized enterprises).
Unlike entities that have to switch to Circular 99, businesses currently using Circular 133 are not subject to systemic changes in accounting practices during this period. Therefore, consistency in accounting methods between 2025 and 2026 will be maintained.
If a micro-enterprise is established on December 20, 2025, and chooses Circular 133, they can confidently apply the condition of consolidating financial statements for no more than 15 months. They will consolidate 11 days of 2025 into the 2026 accounting period. This significantly saves the business time and costs on accounting and auditing services in the early days of operation. This is a strategic point that business owners need to discuss thoroughly with their accounting department when deciding on an accounting system right from the initial registration stage.
For busy startups, using online accounting services Tracking these timelines is an extremely smart and cost-effective option.
Corporate income tax exemption policy under Decree 20/2026/ND-CP
One extremely positive piece of information accompanying the stringent reporting regulations is the tax incentive policy. To boost the private sector after the implementation of Resolution 198/2025/QH15, the Government issued Decree 20/2026/ND-CP guiding the exemption of corporate income tax for new businesses.
Even if a business cannot meet the condition of consolidating financial statements for no more than 15 months and must submit separate reports for 2025, it can still benefit from the tax exemption policy for the first three years if it meets two core conditions:
Condition 1: The applicant must be a small or medium-sized enterprise registering for the first time.
Businesses must belong to the small and medium-sized enterprise (SME) group, including household businesses converting into enterprises or newly registered startups. The initial registration requirements aim to eliminate the practice of "transferring ownership" to benefit from incentives. When businesses prepare their first year's financial statements, even if they are not eligible for the condition of consolidating financial statements for no more than 15 months, they must still record all revenue and expenses to determine the amount of tax exempted.
Condition 2: Not subject to business restructuring.
Decree 20/2026/ND-CP clearly stipulates that newly established businesses resulting from mergers, consolidations, divisions, separations, or conversions of business types from previously operating entities will not be eligible for the 3-year tax exemption. This policy is only for truly "new blood" inflows into the economy.
Understanding these conditions provides businesses with greater peace of mind. Even if they have to painstakingly prepare a separate report for the last few days of 2025 (due to not meeting the technical requirement of consolidating financial statements for no more than 15 months as stipulated in the circular), the benefits from the corporate income tax exemption for the next three years are enormous, fully offsetting the initial compliance costs.
Guidelines for preparing documents and settling accounts for businesses established at the end of 2025.
Below are the steps accountants need to take to ensure compliance with both accounting and tax regulations, given the current divergence in rules regarding the consolidation of financial statements for no more than 15 months:
- Step 1 – Review the Business License issuance date: If the issuance date falls between October 1, 2025 and December 31, 2025, the business is subject to consolidated reporting review.
- Step 2 – Determine the applicable accounting regime: If Circular 99/2025/TT-BTC is chosen, separate financial statements for 2025 are mandatory. The condition of consolidating financial statements for no more than 15 months is not permitted. If Circular 133/2016/TT-BTC is chosen, the 2025 and 2026 financial statements may be consolidated, provided the total period does not exceed 15 months.
- Step 3 – Notify the tax authorities: If the business is eligible for consolidation, a written notification must be sent to the directly managing tax authority to avoid being automatically flagged for late submission of the 2025 financial statements by the system.
- Step 4 – Prepare tax exemption documents: Fill out the forms according to Decree 20/2026/ND-CP along with the first year's corporate income tax return to activate the 3-year tax exemption benefit.
Thorough preparation of the above steps will help businesses navigate the first tax year smoothly. Whether or not you can consolidate financial statements (as long as they are not consolidated for more than 15 months), the accuracy of the data remains the top priority.
Conclude
For businesses established between December 10, 2025 and December 31, 2025, the best advice is to proactively prepare separate financial statements for 2025 according to the guidelines in Circular 66/QLKT-DN. Although the condition of consolidating financial statements for no more than 15 months cannot be applied, with the support from the corporate income tax exemption policy under Decree 20/2026/ND-CP, the financial pressure on newly established businesses has been significantly reduced. Accountants need to regularly update themselves on guidelines from the Ministry of Finance to take the right steps and protect the best interests of their businesses.
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Content production by: Mr. Le Hoang Tuyen – Founder & CEO of MAN – Master Accountant NetworkCPA Vietnam auditors with over 30 years of experience in accounting, auditing, and financial consulting.
