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The audit of an FDI company's financial statements is a mandatory annual obligation carried out by an independent audit firm. For a financial year ending 31 December, the annual financial statements must be filed by 31 March of the following year at the latest, which in practice leaves only about 12 weeks for both closing the books and the audit. This article breaks those 12 weeks into concrete tasks, following the approach the accounting team at ACCA Consulting Vietnam uses with its FDI clients.
1. Why are FDI financial statement audits so often late?
Audits are rarely late because the audit firm is slow. The cause usually lies with the company: figures not yet closed, documents sent piecemeal, and drawn-out debates over audit adjustments. Meanwhile, many other tasks fall due at the same time: the corporate income tax (CIT/TNDN) finalization, the personal income tax (PIT/TNCN) finalization and reporting to the parent company.
| Task | Statutory deadline | Depends on |
|---|---|---|
| File the annual (audited) financial statements | 31 March | Issuance of the audit report |
| CIT finalization | 31 March | Figures after audit adjustments |
| PIT finalization by the income-paying organization | 31 March | Closed full-year payroll |
| Q4 provisional CIT payment and the 80% check | 30 January (Q4 provisional payment) | Full-year profit estimate |
The four quarterly provisional CIT payments together must not be less than 80% of the tax payable per the finalization. If the audit significantly increases profit and this is discovered late, the company may have to pay late-payment interest on the shortfall. That alone is reason enough to start early.
2. A 12-week countdown to the filing deadline
- Before 31 December
Sign the audit engagement, agree the timetable, plan the counts of cash, inventory and fixed assets
- Weeks 1–3 (January)
Close the books; reconcile bank, receivables/payables and intercompany balances; book accruals; revalue foreign currency balances
- Weeks 4–5
Complete draft financial statements and the trial balance; send the full PBC list to the auditors
- Weeks 6–8
Auditors' fieldwork; answer queries within 48 hours; send supplementary documents
- Weeks 9–10
Discuss and agree audit adjustments; update the CIT finalization with the adjusted figures
- Week 11
Review the draft audit report, notes and management letter; submit to the board of directors for approval
- Week 12
Sign and issue; file the audited financial statements and the finalization returns; archive the files
Illustrative example for a small or medium-sized company; companies subject to a group audit usually need to compress weeks 1–5.
View as table
| Closing and reconciliations | 3 tuần |
| Draft financial statements and PBC | 2 tuần |
| Audit fieldwork | 3 tuần |
| Adjustments and tax finalization | 2 tuần |
| Approval, issuance and filing | 2 tuần |
3. The PBC list: documents to send to the auditors
PBC (Prepared by Client) is the list of documents the company prepares itself. Sending everything in one go, with consistent file names, shortens fieldwork considerably.
- Trial balance, general ledger and subsidiary ledgers for all accounts
- Bank statements and bank balance confirmations as at 31 December
- Count minutes for cash, inventory and fixed assets
- Reconciliations of receivables, payables and intercompany balances
- Depreciation schedules and schedules for prepaid expense allocation and accruals
- Full-year VAT and PIT returns; quarterly provisional CIT schedules
- Major contracts, loan agreements and contracts with related parties
- Payroll, employment contracts and social insurance payment records
4. Handling audit adjustments
Audit adjustments are the part most likely to cause disputes. An effective approach:
- Ask the auditors to send their list of proposed adjustments early rather than at the end of fieldwork.
- Classify them: adjustments agreed immediately, adjustments requiring more documents, and adjustments not agreed.
- For adjustments you do not agree with, prepare your reasoning and supporting documents in writing.
- Update the books and the CIT finalization return immediately so the two sets of figures match.
- Keep the signed agreement minutes to explain the position to the parent company and the tax authority.
5. How can an outsourced accountant help during audit season?
ACCA Consulting Vietnam is not an audit firm and does not issue audit reports. Our role is on the company's side: closing the books, preparing draft financial statements, preparing the PBC, answering auditors' queries and updating the tax finalization. If you have not yet chosen an audit firm, see choosing an audit firm for an FDI company; if this is your first year of operation, see the first-year audit checklist.
FAQ
Can a small FDI company with low revenue be exempt from audit?
No. Foreign-invested enterprises are subject to a mandatory annual financial statement audit regardless of revenue size.
If the financial year differs from the calendar year, how is the deadline calculated?
The deadline is the last day of the third month after the end of the financial year. The 12-week schedule shifts accordingly.
Should the audit engagement be signed after the books are closed?
It is better to sign before the financial year ends, so the auditors can attend the stock counts and you can secure their schedule during peak season.
Audit-ready from December
ACCA Consulting Vietnam supports FDI accounting teams with closing, the PBC, audit adjustments and tax finalization. Get advice on our accounting services.
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