Dang Ngoc Minh, deputy head of the General Department of Taxation, said 57.3 percent of the amount is the back tax, 35.2 percent is a penalty for delayed payment and the remaining 7.5 percent is a penalty for incorrect filing.

"The company can request a review or file a lawsuit."

A Coca-Cola spokesperson said tax authorities had recently concluded an investigation of the 2007-15 business period, and found the company had made "minor errors" in describing its business operations which had led to a failure to file for taxes.

Though it disagrees with some of the tax authorities’ conclusions, the company would nevertheless comply with the laws, he said.

But an official from the Ho Chi Minh City Tax Department said Coca-Cola has only paid VND38.2 billion ($1.6 million) as of Thursday.

Coca-Cola entered Vietnam in 1994, and broke even only in 2013 despite double-digit revenue growth, according to the department.

Since the company reported accumulated losses of VND3.77 trillion ($162.5 million) as of 2011, it was exempt from corporate income tax.

HCMC has named Coca-Cola among businesses it suspects of transfer pricing fraud to evade tax.