Circular 32/2026/TT-BTC guidance on value added tax, corporate income tax and personal income tax for cryptoasset trading, transfer and business

CIRCULAR

Providing guidance on value added tax, corporate income tax and personal income tax for cryptoasset trading, transfer and business

Pursuant to Law No. 67/2025/QH15 on Corporate Income Tax;

Pursuant to Law No. 48/2024/QH15 on Value-Added Tax, which is amended and supplemented by Law No. 90/2025/QH15 and Law No. 149/2025/QH15;

Pursuant to Law No. 04/2007/QH12 on Personal Income Tax, which is amended and supplemented by Law No. 26/2012/QH12, Law No. 71/2014/QH13 and Law No. 56/2024/QH15;

Pursuant to the Government’s Decree No. 320/2025/ND-CP detailing a number of articles of, and providing measures to organize and implement, the Law on Corporate Income Tax;

Pursuant to the Government’s Decree No. 181/2025/ND-CP detailing a number of articles of the Law on Value-Added Tax, which is amended and supplemented by Decree No. 359/2025/ND-CP;

Pursuant to the Government’s Decree No. 65/2013/ND-CP detailing a number of articles of the Law on Personal Income Tax and the Law Amending and Supplementing a Number of Articles of the Law on Personal Income Tax which is amended and supplemented by Decree No. 12/2015/ND-CP;

Pursuant to the Government’s Resolution No. 05/2025/NQ-CP on the pilot implementation of the cryptoasset market in Vietnam;

Pursuant to the Government’s Decree No. 29/2025/ND-CP defining the functions, tasks, powers and organizational structure of the Ministry of Finance, which is amended and supplemented by Decree No. 166/2025/ND-CP;

At the proposal of the Director of the Department for Management and Supervision of Tax, Fees and Charges Policies

The Minister of Finance promulgates a circular providing guidance on value added tax, corporate income tax and personal income tax for cryptoasset trading, transfer and business.

Article 1. Scope of regulation

This Circular providing guidance on value-added tax, corporate income tax and personal income tax and the timing for determining revenue and income for cryptoasset trading, transfer and business under the Government’s Resolution No. 05/2025/NQ-CP of September 9, 2025 on the pilot implementation of the cryptoasset market in Vietnam.

Article 2. Subjects of application

This Circular applies to organisations and individuals related to the scope of regulation specified in Article 1 of this Circular.

Article 3. Value-added tax policy

1. Cryptoasset transfer and trading not subject to value-added tax.

2. For activities not specified in Clause 1 of this Article, the law on value-added tax shall apply.

Article 4. Corporate income tax policy

1. Investors being organisations that are established and operating under Vietnam’s law and have income from cryptoasset transfer activities shall be subject to corporate income tax at a rate of 20%, except the cases specified in Clauses 2 and 3, Article 10 of Law No. 67/2025/QH15 on Corporate Income Tax.

Taxable income from cryptoasset transfer activities in a period shall be determined based on the selling price of cryptoassets minus the purchase price of the transferred cryptoassets and transfer-related expenses supported by invoices and documentation.

2. Enterprises that are cryptoasset service providers as defined in Clause 3, Article 3 of Resolution No. 05/2025/NQ-CP and have income from cryptoasset service provision shall be subject to corporate income tax at a rate of 20%, except the cases specified in Clauses 2 and 3, Article 10 of Law No. 67/2025/QH15 on Corporate Income Tax.

3. Investors being organizations that are established under foreign laws and conduct cryptoasset transfer activities through cryptoasset service providers shall be subject to corporate income tax at a rate of 0.1% on the revenue of each transfer.

Article 5. Personal income tax policy

Investors being individuals (regardless of their residence or non-residence) that conduct cryptoasset transfer activities through cryptoasset service providers shall be subject to personal income tax at a rate of 0.1% on the price of each transfer.

Article 6. Timing for determination of revenue and income

The timing for determining revenue and income for cryptoasset transfers must comply with the provisions of the corporate income tax and personal income tax laws regarding the timing for determining revenue and income for securities transfers and the law on cryptoassets.

Article 7. Effect

1. This Circular takes effect on March 27, 2026 and shall be implemented according to the pilot implementation period specified in Clauses 2 and 3, Article 18 of Resolution No. 05/2025/NQ-CP or until there is a tax policy for the cryptoasset market in Vietnam as specified in Clause 9, Article 4 of Resolution No. 05/2025/NQ-CP.

2. The contents not guided in this Circular shall be implemented in accordance with current tax laws.-

For the Minister of Finance

Deputy Minister

CAO ANH TUAN