Law on Corporate Income Tax 2025, No. 67/2025/QH15

LAW

On Corporate Income Tax^[1]

Pursuant to the Constitution of the Socialist Republic of Vietnam;

The National Assembly promulgates the Law on Corporate Income Tax.

Chapter I

GENERAL PROVISIONS

Article 1. Scope of regulation

This Law prescribes taxpayers, taxable income, tax-exempt income, tax bases, tax calculation methods, and incentives with respect to corporate income tax (CIT).

Article 2. Taxpayers

1. CIT payers are organizations carrying out goods and service production and business activities that generate taxable incomes as prescribed in this Law (below referred to as enterprises), including:

a/ Enterprises established under Vietnam’s law;

b/ Enterprises established under foreign laws (below referred to as foreign enterprises) with or without Vietnam-based permanent establishments;

c/ Cooperatives and unions of cooperatives established under the Law on Cooperatives; 

d/ Non-business units established under Vietnam’s law;

dd/ Other organizations conducting income-generating production and business activities.

2. Enterprises having taxable incomes as specified in Article 3 of this Law shall pay CIT as follows:

a/ Enterprises established under Vietnam’s law shall pay tax on taxable incomes generated in Vietnam and taxable incomes generated outside Vietnam;

b/ Foreign enterprises with Vietnam-based permanent establishments shall pay tax on taxable incomes generated in Vietnam and taxable incomes generated outside Vietnam that are related to the operation of such establishments;

c/ Foreign enterprises with Vietnam-based permanent establishments shall pay tax on taxable incomes generated in Vietnam that are not related to the operation of such establishments;

d/ Foreign enterprises without Vietnam-based permanent establishments, including also enterprises engaged in e-commerce business or digital platform-based business, shall pay tax on taxable incomes generated in Vietnam.

3. Foreign enterprises’ permanent establishments are production and business establishments through which foreign enterprises conduct part or the whole of production and business activities in Vietnam, including:

a/ Branches, executive offices, factories, workshops, means of transport, oil mines, gas fields, mines or other places of extraction of natural resources in Vietnam;

b/ Construction sites, construction works, and installation and assembly projects;

c/ Establishments providing services, including also consultancy services through employees or other organizations or individuals;

d/ Agents for foreign enterprises;

dd/ Vietnam-based representatives, in case they are competent to conclude contracts in the name of foreign enterprises, or in case they are not competent to conclude contracts in the name of foreign enterprises but regularly deliver goods or provide services in Vietnam;

e/ E-commerce platforms or digital platforms through which the foreign enterprises provide goods and services in Vietnam.

4. The Government shall detail this Article.

Article 3. Taxable incomes

1. Incomes subject to CIT include income from goods and service production and business activities and other incomes specified in Clause 2 of this Article.

2. Other incomes include:

a/ Income from the transfer of capital, transfer of the capital-contributing rights or transfer of securities;

b/ Income from the transfer of real estate, excluding income from transfer of real estate by real estate enterprises;

c/ Income from the transfer of investment projects, transfer of the right to participate in investment projects, or transfer of the right to explore, extract and process minerals;

d/ Income from the transfer, lease or liquidation of assets, including valuable papers, excluding real estate;

dd/ Income from asset use rights or asset ownership rights, including also income from intellectual property rights and technology transfer;

e/ Income from interests on savings deposits, interests on loans, and sale of foreign currencies, excluding income from credit activities of credit institutions;

g/ Amounts included in advance in expenses but not used or not fully used which an enterprise does not account as a reduction of deductible expenses; revenue from written-off bad debts which are now recovered; revenue from payable debts of unidentified creditors; and omitted income from business activities of previous years which is now found;

h/ The difference between revenue from fines and compensation for economic contract breaches or bonuses for good fulfillment of contractual commitments;

i/ Donations and grants received in cash or in kind;

k/ The difference arising from asset revaluation in accordance with law for capital contribution, transfer upon the merger, consolidation, division, splitting, ownership transfer or enterprise transformation;

l/ Income from business cooperation contracts;

m/ Income from overseas production and business activities;

n/ Income of public non-business units from lease of public assets;

o/ Other incomes, excluding tax-exempt incomes specified in Article 4 of this Law.

3. Foreign enterprises’ taxable income generated in Vietnam as specified at Points c and d, Clause 2, Article 2 of this Law is the received income originating in Vietnam, regardless of the location where the business activities are conducted.

4. A Vietnamese enterprise carrying out offshore investment activities and earning income from production and business activities in a foreign country during a tax period is entitled to deduction of its CIT amount payable under the law of the host country from the CIT amount payable in Vietnam but the to-be-deducted amount must not exceed the CIT amount computed under Vietnam’s law on corporate income tax.

5. For an enterprise subject to top-up CIT based on the Income Inclusion Rule (IIR) in accordance with law, the payable top-up CIT amount shall be deducted from the CIT amount payable in Vietnam in accordance with this Law.

6. The Government shall detail this Article.

Article 4. Tax-exempt incomes

1. Income from fishing activities; income of enterprises from the production of products from planted trees, planted forests, livestock production, aquaculture, and agricultural and aquatic product processing (including also cases of purchasing agricultural and aquatic products for processing) in geographical areas with extremely difficult socio-economic conditions; income of cooperatives and unions of cooperatives from the production of products from planted trees, planted forests, livestock production, aquaculture, and agricultural and aquatic product processing (including also cases of purchasing agricultural and aquatic products for processing), and salt production. 

2. Income of cooperatives and unions of cooperatives operating in the fields of agriculture, forestry, fisheries and salt production in geographical areas with difficult socio-economic conditions or geographical areas with extremely difficult socio-economic conditions.

3. Income from the provision of technical services directly for agriculture.

4. Income from the performance of contracts on scientific research, technology development, and innovation and digital transformation; income from the sale of products turned out with the application of new technologies for the first time in Vietnam; and income from the sale of products from trial production in the course of trial production, including controlled trial production as prescribed by law. The incomes specified in this Clause are exempt from CIT for no more than 3 years.

5. Income from goods and service production and business activities of enterprises each employing people with disabilities, persons who have undergone drug addiction treatment and persons infected with human immunodeficiency virus/acquired immune deficiency syndrome (HIV/AIDS) accounting for an annual average of 30% or more of employees and each having an annual average of employees of 20 or more, excluding enterprises operating in the fields of finance and real estate business.

6. Income from vocational education and vocational training activities exclusively for ethnic minorities, people with disabilities, children in special circumstances and persons involved in social evils.

7. Income divided from capital contribution, share purchase, joint ventures and association with domestic enterprises after CIT has been paid in accordance with this Law, even if the party acquiring capital contributions or issuing shares or the party to joint venture or association is entitled to CIT incentives.

8. Received donations for educational, cultural, art, charitable, humanitarian and other social activities in Vietnam; donations received from non-associated enterprises, and domestic and foreign organizations and individuals for scientific research, technology development, and innovation and digital transformation; direct support from the state budget and from the Investment Support Fund established by the Government; and the State’s compensation in accordance with law.

If an enterprise uses the donations specified in this Clause for improper purposes, it will be subject to the retroactive collection of tax and sanctions in accordance with law.

9. The difference from asset revaluation in accordance with law to serve equitization and reorganization of enterprises in which the State holds 100% of charter capital.

10. Income from the transfer of emission reduction certificates, the first transfer of carbon credits after issuance by enterprises for which emission reduction certificates or carbon credits are issued; income from interests on green bonds; and income from the first transfer of green bonds after issuance.

11. Income (including also interests on bank deposits, interests on government bonds and interests on treasury bills) from performance of the State’s assigned tasks in the following cases:

a/ Income of the Vietnam Development Bank from development investment credit and export credit activities;

b/ Income of the Vietnam Bank for Social Policies from credit activities for the poor and other policy beneficiaries;

c/ Income of the Vietnam Asset Management Company (VAMC);

d/ Income from revenue-generating activities of state financial funds and other funds and organizations of the State that operate for not-for-profit purposes as specified or decided by the Government or the Prime Minister.

12. The non-divided income amount of establishments engaged in socialization of education-training and healthcare activities and activities in other fields, which is retained for investment in the development of such establishments to meet the Government-set minimum ratio; the income amount forming the non-divided common fund and non-divided common assets of cooperatives and unions of cooperatives established and operating in accordance with the law on cooperatives.

13. Income from technology transfer in fields prioritized for transfer of technologies to organizations and individuals in geographical areas with extremely difficult socio-economic conditions.

14. Income of public non-business units from the provision of public non-business services, including:

a/ Basic and essential public non-business services on the list of state budget-funded public non-business services promulgated by a competent agency;

b/ Public non-business services requiring the State’s support in terms of operating funds as service provision costs have not yet been fully included in service prices;

c/ Public non-business services in geographical areas with extremely difficult socio-economic conditions.

15. The Government shall detail this Article.

Article 5. Tax period

1. The CIT period is calendar year or fiscal year as chosen by enterprises, except the case specified in Clause 2 of this Article. If an enterprise chooses to apply a fiscal year other than a calendar year, it shall notify such to the managing tax administration agency before the application.

2. The tax period for the enterprises specified at Points c and d, Clause 2, Article 2 of this Law must comply with the law on tax administration.

Chapter II

TAX BASES AND TAX CALCULATION METHODS

Article 6. Tax bases

Tax bases include taxed income and tax rate.

Article 7. Determination of taxed income

1. Taxed income in a tax period shall be determined as follows:

2. Taxable income specified in Clause 1 of this Article shall be determined as follows:

3. Taxable income from production and business activities of an enterprise that conducts multiple production and business activities in a tax period is the total income from all production and business activities. If a production or business activity suffers a loss, the loss shall be cleared against the taxable income from income-generating production and business activities as chosen by the enterprise (excluding income from real estate transfer, investment project transfer, or transfer of the right to participate in investment projects, which may not be cleared against the income from production and business activities currently entitled to tax incentives). The income left after the clearing shall be subject to the CIT rate applicable to income-generating production and business activities.

4. Taxable income from the transfer of mineral exploration, exploitation and processing investment projects; transfer of the right to participate in mineral exploration, exploitation and processing investment projects; or transfer of the right to explore, exploit and process minerals shall be separately determined for tax declaration and payment, and losses and profits may not be cleared against production and business activities in a tax period.

Article 8. Turnover

1. Turnover for calculating taxable income is the entire proceeds from goods sale and processing and service provision, including also subsidies, surcharges and extra charges receivable by an enterprise, regardless of whether such proceeds have been collected or not.

2. The Government shall detail this Article.

Article 9. Deductible and non-deductible expenses upon determination of taxable incomes

1. Except the expenses specified in Clause 2 of this Article, an enterprise may deduct expenses upon the determination of taxable income if fully satisfying the following conditions:

a/ Actual expenses related to its production and business activities, including also additional expenses deducted based on the percentage of actual expenses arising in the tax period related to its research and development activities;

b/ Other actual expenses, including:

b1/ Expense for national defense and security education, training, operation of militia and self-defense forces, and other national defense and security tasks as specified by law;

b2/ Expense as support for activities of the Party organization and socio-political organizations within the enterprise;

b3/ Expense for vocational education and training for employees as specified by law;

b4/ Actual expense for HIV/AIDS prevention and control activities at its workplace;

b5/ Donations for education, healthcare and culture; donations for prevention, combat, and remediation of consequences of disasters and epidemics, construction of great solidarity houses, houses of gratitude, and houses for policy beneficiaries as specified by law; donations as specified by the Government and the Prime Minister for localities in geographical areas with extremely difficult socio-economic conditions; and donations for scientific research, technological development, and innovation and digital transformation;

b6/ Expense for scientific research, technological development, and innovation and digital transformation;

b7/ The uncompensated value of losses caused by disasters, epidemics or other force majeure events;

b8/ Actual expense for personnel seconded to participate in the governance, administration and control of credit institutions placed under special control, or commercial banks subject to mandatory transfer as specified by the Law on Credit Institutions;

b9/ Several expenses serving its production and business activities but not yet corresponding to the turnover generated in the tax period as specified by the Government;

b10/ Several expenses as support for the construction of public works and also for its production and business activities;

b11/ Expenses related to greenhouse gas emission reduction for carbon neutrality and net-zero emission and reduction of environmental pollution that are also related to its production and business activities;

b12/ Several contributions to funds established under the Prime Minister’s decisions and the Government’s regulations;

c/ Expenses accompanied with sufficient non-cash payment invoices and documents as prescribed by law, except specific cases specified by the Government.

2. Non-deductible expenses upon the determination of taxable income include:

a/ Expenses not fully satisfying the conditions specified in Clause 1 of this Article;

b/ Fines for administrative violations;

c/ Expenses offset by other funding sources;

d/ Expenses in excess of the Government-specified levels with respect to: business management costs allocated by foreign enterprises to their permanent establishments in Vietnam; expenses for hiring the management of prize-winning video games and casino business; payments for interests on loans for enterprises with related-party transactions; expenses as direct welfare for employees; contributions to supplementary retirement insurance as specified by the Law on Social Insurance or social security funds, and for payment of voluntary retirement insurance premiums and life insurance premiums for employees;

dd/ The deductions that are improperly made or exceed the levels stated in the regulations on making of deductions for risk provisions;

e/ Deductions for fixed asset depreciation that are improperly made or exceed the law-specified levels;

g/ Amounts included in advance in expenses in contravention of law;

h/ Salaries and wages of owners of sole proprietorships, individual owners of single-member limited liability companies; remuneration paid to enterprise founders who do not personally administer production and business activities; salaries, wages and other amounts accounted as expenses for payment to employees but not actually paid or paid without invoices or documents as specified by law;

i/ The loan interest amount paid corresponding to the deficient amount of charter capital; the loan interest earned from investment activities that has been included in the investment value; loan interests for implementing oil and gas prospecting, exploration and extraction contracts; interests on loans for production and business activities of subjects other than credit institutions that exceed the levels specified in the Civil Code;

k/ Recoverable expenses exceeding the percentage stated in the approved oil and gas contracts; in case an oil and gas contract does not state the expense recovery percentage, the expense exceeding the Government-specified level may not be included in deductible expenses;

l/ The value-added tax amount already credited; the value-added tax amount paid by the credit method; the input value-added tax amount for the value of passenger cars with 9 seats or less that exceeds the Government-specified level; CIT; other taxes, charges, fees and revenues that are not allowed to be included in expenses as specified by law and late-payment interests as specified by the law on tax administration.

The value-added tax amount paid by the credit method specified at this Point is exclusive of the input value-added tax amount for goods and services directly related to the enterprise’s production and business activities that has not been fully credited but is ineligible for tax refund.

The input value-added tax amount that has been included in deductible expenses may not be cleared against the output value-added tax amount;

m/ Expense not corresponding to the taxed revenue, except the expenses specified at Point b, Clause 1 of this Article; expenses failing to meet the conditions and contents specified by specialized laws;

n/ Donations, except those specified at Item b5, Point b, Clause 1 of this Article;

o/ Expenses for capital construction investment during the investment phase to form fixed assets; expenses directly related to the increase or decrease of the enterprise’s equity;

p/ Expenses for business activities in the fields of banking, insurance, lottery, securities, and BT, BOT and BTO contracts that are improperly paid or exceed the law-specified limits;

q/ Other expenses.

3. The Government shall detail this Article, including also the provisions on the additional expense level, conditions, time and scope of application for expenses for research and development activities of enterprises as specified at Point a, Clause 1 of this Article.

The Ministry of Finance shall specify dossiers of expenses included in the deductible expenses referred to at Points b and c, Clause 1 of this Article.

Article 10. Tax rates

1. The CIT rate is 20%, except the cases specified in Clauses 2, 3 and 4 of this Article and the subjects entitled to tax rate incentives specified in Article 13 of this Law.

2. The tax rate of 15% shall be applied to enterprises with the annual total turnover not exceeding VND 3 billion.

3. The tax rate of 17% shall be applied to enterprises with the annual total turnover exceeding VND 3 billion but not exceeding VND 50 billion.

The turnover used as a basis for determining whether an enterprise is entitled to the tax rates of 15% or 17% as specified in Clause 2 or 3 of this Article is the total turnover of the preceding CIT period. The determination of the total turnover for use as a basis for application must comply with the Government’s regulations.

4. The CIT rate applicable other cases is:

a/ Between 25% and 50%, for oil and gas prospecting, exploration and extraction activities. Based on the location, extraction conditions and reserves of oil and gas fields, the Prime Minister shall decide on the specific tax rate appropriate for each oil and gas contract;

b/ Fifty percent, for activities of exploring and exploiting precious and rare natural resources (including platinum, gold, silver, tin, wolfram, antimony, gemstones, rare earths and other precious and rare natural resources as specified by law); or 40%, in case 70% or more of the allocated area of the mines is located in geographical areas with extremely difficult socio-economic conditions.

Article 11. Tax calculation method

1. The payable CIT amount in a tax period is the taxed income multiplied by the tax rate, except the case specified in Clause 2 of this Article.

2. The Government shall prescribe the payable CIT amount calculated based on a percentage (%) of turnover for the following cases:

a/ Enterprises specified at Points c and d, Clause 2, Article 2 of this Law; subjects obliged to declare and pay tax, time and method for determining the turnover for calculation of taxable income generated in Vietnam;

b/ Enterprises with the annual total turnover not exceeding VND 3 billion as specified in Clause 2, Article 10 of this Law, in case it is possible to determine turnover but impossible to determine expenses for and income from production and business activities;

c/ Cooperatives, unions of cooperatives, non-business units and other organizations specified at Points c, d, and dd, Clause 1, Article 2 of this Law that conduct goods and service production and business activities generating income subject to CIT (excluding tax-exempt incomes specified in Article 4 of this Law), and can account the turnover but cannot determine expenses for and income from production and business activities.

Chapter III

CORPORATE INCOME TAX INCENTIVES

Article 12. Principles and subjects of application of CIT incentives

1. Enterprises are entitled to CIT incentives according to the sectors and trades eligible for CIT incentives and geographical areas eligible for CIT incentives as specified in this Article. CIT incentive levels must comply with Articles 13 and 14 of this Law.

In case another law contains provisions on CIT incentives different from those of this Law, the provisions of this Law shall prevail, except cases in which the Law on the Capital and resolutions provide special and specific mechanisms and policies of the National Assembly.

If an enterprise is entitled to multiple different tax incentive levels under this Law for the same income, it may choose the most beneficial tax incentive level.

2. Sectors and trades eligible for CIT incentives include:

a/ Hi-tech application, venture investment in the development of high technologies on the list of high technologies prioritized for investment development in accordance with the Law on High Technologies; application of strategic technologies in accordance with law; hi-tech incubation and hi-tech enterprise incubation; investment in the construction and commercial operation of hi-tech incubators and hi-tech enterprise incubators;

b/ Manufacture of software products; manufacture of cyberinformation security products and provision of cyberinformation security services meeting the conditions specified in the law on cyberinformation security; manufacture of key digital technology products and provision of key digital technology services, manufacture of electronic devices according to the law on the digital technology industry; research and development, designing, manufacture, packaging and testing of semiconductor chip products; construction of artificial intelligence data centers;

c/ Manufacture of of supporting industry products on the Government-specified List of products of supporting industry products prioritized for development that meet one of the following criteria:

c1/ Being supporting industry products for high technologies according to the Law on High Technologies;

c2/ Being supporting industry products for the manufacture of products of the textile-garment, footwear-leather and electronic-informatic industries (including also semiconductor designing and manufacture), automobile manufacture and assembly, and mechanical engineering that, by the effective date of this Law, have not yet been produced domestically or that have been produced domestically but are still required to meet the European Union’s technical standards or equivalent standards (if any) as specified by the Minister of Industry and Trade;

d/ Generation of renewable energy, clean energy, or energy from waste disposal; environmental protection; production of composite materials, lightweight construction materials, and precious and rare materials; production in the field of national defense and security, and production of industrial mobilization products according to the law on national defense and security industry and industrial mobilization; and production of key chemical industry products and key mechanical products in accordance with law;

dd/ Investment in development of water plants, power plants, water supply and drainage systems, bridges, roads, railways, airports, seaports, river ports, aerodromes, railway stations, and other infrastructure works of special importance under the Prime Minister’s decisions;

e/ Hi-tech enterprises and hi-tech agricultural enterprises defined in the Law on High Technologies; and science and technology enterprises defined in the Law on Science, Technology and Innovation;

g/ Investment projects in the manufacture fields each meeting the following conditions: 

g1/ Having an investment capital amount of at least VND 12 trillion, and planning to disburse the total registered investment capital amount within 5 years from the date of being licensed to make investment under the law on investment;

g2/ Using technologies that meet the requirements of the Minister of Science and Technology;

h/ Being eligible for special investment incentives and supports as specified in Clause 2, Article 20 of the Law on Investment. The Government shall provide in detail the time of disbursement of the total registered investment capital amount for the projects specified at this Point; 

i/ Planting, tending and protecting forests; producing, propagating and hybridizing plant varieties and animal breeds; investing in post-harvest preservation of agricultural products and preservation of agricultural and aquatic products and food; producing, exploiting and refining salt, except salt production specified in Clause 1, Article 4 of this Law;

k/ Forest farming;

l/ Products from planted trees, planted forests, livestock production, aquaculture, and agricultural and aquatic product processing.

Income from agricultural and aquatic product processing referred to at this Point must meet the conditions specified in Clause 1, Article 4 of this Law;

m/ Manufacture of high-grade steel; production of energy-efficient products; manufacture of machinery and equipment serving agro-forestry-fisheries production and salt production; production of irrigation equipment; and production of cattle, poultry and aquatic feeds;

n/ Manufacture and assembly of automobiles; manufacture of other digital technology products;

o/ Investment in and commercial operation of technical establishments supporting small- and medium-sized enterprises and small- and medium-sized enterprise incubators; investment in and commercial operation of co-working spaces supporting innovative startup small- and medium-sized enterprises in accordance with the Law on Support for Small- and Medium-sized Enterprises;

p/ People’s credit funds, microfinance institutions and cooperative banks;

q/ Cooperatives and unions of cooperatives operating in the fields of agriculture, forestry, fisheries and salt production;

r/ Socialization of education-training, vocational training, healthcare, cultural, sports and environmental activities based on the Prime Minister-issued List of types, sizes and criteria for such activities; and judicial assessment;

s/ Investment in the construction of social housing for sale, lease or lease-purchase to housing support policy beneficiaries in accordance with the Housing Law;

t/ Publishing in accordance with the Publication Law;

u/ Press (including also advertising in the press) in accordance with the Press Law.

3. Geographical areas eligible for CIT incentives specified by the Government include:

a/ Geographical areas with extremely difficult socio-economic conditions;

b/ Geographical areas with difficult socio-economic conditions;

c/ Economic zones, hi-tech parks, hi-tech agricultural zones, and digital technology parks.

4. The Government shall provide the application of tax incentives to the following cases:

a/ Cases of application of tax incentives based on geographical area criterion;

b/ Cases of application of tax incentives in the fields of agriculture, forestry, fisheries and salt production;

c/ Cases in which an enterprise’s investment project (including also new investment projects, expanded investment projects, hi-tech enterprises, hi-tech agricultural enterprises, and science and technology enterprises) has generated turnover or income in the first tax period while the period during which the enterprise is entitled to tax incentives is shorter than 12 months.

5. Enterprises established or enterprises having investment projects from the merger, consolidation, division, splitting, ownership transfer or enterprise transformation shall fulfill CIT obligations (even fines, if any), and concurrently take over the CIT incentives (even losses not yet carried forward) of the enterprises or investment projects prior to the merger, consolidation, division, splitting, ownership transfer or enterprise transformation, provided that they still satisfy the conditions for eligibility for CIT incentives and the conditions for carrying forward losses specified by law.

Article 13. Preferential tax rates

1. The tax rate of 10% for 15 years shall be applied to:

a/ Enterprises’ income from the implementation of new investment projects specified at Points a, b, c, d and dd, Clause 2, Article 12 of this Law; and income of the enterprises specified at Point e, Clause 2, Article 12 of this Law;

b/ Enterprises’ income from the implementation of the investment projects specified at Points g and h, Clause 2, Article 12 of this Law;

c/ Enterprises’ income from the implementation of new investment projects in the geographical areas specified at Point a, Clause 3, Article 12 of this Law;

d/ Enterprises’ income from the implementation of new investment projects in hi-tech parks, hi-tech agriculture zones, digital technology parks; new investment projects in economic zones located in geographical areas eligible for tax incentives as specified at Points a and b, Clause 3, Article 12 of this Law. In case an investment project is implemented in an economic zone located in a geographical area eligible for tax incentives and a geographical area ineligible for tax incentives, the determination of tax incentives for the project shall be specified by the Government.

2. The tax rate of 10% shall be applied to:

a/ Enterprises’ income from activities in the sectors or trades specified at Points k and l, Clause 2, Article 12 of this Law in geographical areas eligible for tax incentives specified at Point b, Clause 3, Article 12 of this Law;

b/ Enterprises’ income from activities in the sectors or trades specified at Points i, r, and s, Clause 2, Article 12 of this Law;

c/ Publishing houses’ income from activities in the sectors or trades specified at Point t, Clause 2, Article 12 of this Law;

d/ Income of cooperatives and unions of cooperatives specified at Point q, Clause 2, Article 12 of this Law that are not located in the geographical areas specified in Clause 3, Article 12 of this Law;

dd/ Press agencies’ income from activities in the sectors or trades specified at Point u, Clause 2, Article 12 of this Law.

3. The tax rate of 15% shall be applied to enterprises’ income from activities in the sectors or trades specified at Point l, Clause 2, Article 12 of this Law that are not located in the geographical areas specified in Clause 3, Article 12 of this Law.

4. The tax rate of 17% for 10 years shall be applied to:

a/ New investment projects of the sectors or trades eligible for tax incentives specified at Points m, n, and o, Clause 2, Article 12 of this Law;

b/ New investment projects implemented in the geographical areas specified at Point b, Clause 3, Article 12 of this Law;

c/ New investment projects in economic zones that are not located in the geographical areas specified at Points a and b, Clause 3, Article 12 of this Law.

5. The tax rate of 17% shall be applied to enterprises’ income falling into the case specified at Point p, Clause 2, Article 12 of this Law.

6. The extension of the period of application and the application of preferential tax rates are as follows:

a/ The Prime Minister shall decide on the extension of the period of application of preferential tax rates for up to 15 years for the following projects:

a1/ New investment projects specified at Points a, b, d and dd, Clause 2, Article 12 of this Law, each with an investment capital amount of at least VND 6 trillion and having great socio-economic impacts that need special promotion;

a2/ Investment projects specified at Point g, Clause 2, Article 12 of this Law, that meet one of the following criteria:

- Producing products and goods that are globally competitive, earning an annual turnover exceeding VND 20 trillion within 5 years after generating turnover;

- Regularly employing over 6,000 workers as determined in accordance with the labor law;

- Investment projects in the field of economic and technical infrastructure, including: development investment in water plants, power plants, water supply and drainage system, bridges, roads, railways, airports, seaports, river ports, aerodromes, railway stations, new energy, clean energy, energy-efficient industries, and oil refinery and petrochemical projects;

b/ For new investment projects specified at Point h, Clause 2, Article 12 of this Law, the Prime Minister shall decide on the application of a tax rate reduced by no more than 50% of the tax rate specified in Clause 1 of this Article; the period of application of the preferential tax rate must not exceed 1.5 times that specified in Clause 1 of this Article and may be extended for no more than 15 years but must not exceed the duration of an investment project.

7. The period of application of the preferential tax rate for income from the implementation of an enterprise’s new investment project specified in this Article (including also the projects specified at Point g, Clause 2, Article 12 of this Law) shall be counted from the first year of turnover generation.

In case the enterprise is issued a hi-tech enterprise certificate, a hi-tech agricultural enterprise certificate, a science and technology enterprise certificate, a hi-tech application project certificate or a letter of confirmation of incentives for projects manufacturing supporting industry products after the enterprise generates turnover, the period of application of the preferential tax rate shall be counted from the year such certificate or letter of confirmation is issued.

Article 14. Tax exemption or reduction

1. Tax exemption for up to 4 years and a 50% reduction of the payable tax amounts for up to subsequent 9 years shall be applied to:

a/ Enterprises’ income falling into the case specified in Clause 1, Article 13 of this Law;

b/ Enterprises’ income falling into the case specified at Point r, Clause 2, Article 12 of this Law for activities carried out in the geographical areas specified at Points a and b, Clause 3, Article 12 of this Law; for activities not carried out in the geographical area specified at Point a or b, Clause 3, Article 12 of this Law, tax exemption for up to 4 years and a 50% reduction of payable tax amounts for up to subsequent 5 years shall be applied.

2. Tax exemption for up to 2 years and a 50% reduction of payable tax amounts for up to subsequent 4 years shall be applied to enterprises’ income falling into the cases specified in Clause 4, Article 13 of this Law.

3. For new investment projects specified at Point h, Clause 2, Article 12 of this Law, the Prime Minister shall decide on the extension of the tax exemption or reduction period not exceeding 1.5 times that specified in Clause 1 of this Article.

4. The tax exemption or reduction period shall be counted from the first year an investment project generates taxable income; if no taxable income is generated in the first 3 years from the first year the project generates turnover, the tax exemption or reduction period shall be counted from the fourth year.

In case the enterprise is issued a hi-tech application project certificate, a hi-tech enterprise certificate, a hi-tech agricultural enterprise certificate, a science and technology enterprise certificate or a letter of confirmation of incentives for projects manufacturing supporting industry products after the enterprise generates turnover, the tax reduction or exemption period shall be counted from the year such certificate or letter of confirmation is issued. In case the enterprise generates no income in the year the certificate or letter of confirmation is issued, the tax exemption or reduction period shall be counted from the first year the enterprise earns income; if the enterprise generates no taxable income for the first 3 years from the year the certificate or letter of confirmation is issued, the tax exemption or reduction period shall be counted from the fourth year from the year the certificate or letter of confirmation is issued.

5. Tax incentives for expanded investment projects:

a/ For an enterprise having an investment project in operation and expanding the scale, raising the capacity or innovating technologies of such project, and applying pollution mitigation or environment improvement solutions in the sectors, trades or geographical areas eligible for CIT incentives as specified in Article 12 of this Law (below referred to as expanded investment), the income increased from expanded investment will be entitled to tax incentives applicable to such project for the remaining period, and the enterprise is not required to separately account the increased income from income from the project’s income;

b/ In case the tax incentive period of the project in operation has expired, the income increased from expanded investment project that meets the criteria specified in Clause 6 of this Article will be entitled to tax exemption or reduction, but not entitled to the preferential tax rate. The tax exemption or reduction period for the income increased from expanded investment is equal to the tax exemption or reduction period applicable to new investment projects in the same sectors, trades or geographical areas eligible for CIT incentives and shall be counted from the year the investment project completely disburses the registered investment capital amount.

The enterprise shall separately account the income increased from expanded investment for use as a basis for application of tax incentives. If separate accounting is impossible, the income from expanded investment activities shall be determined based on the ratio of the historical costs of new fixed assets used for production and business activities to the total historical costs of fixed assets of the enterprise;

c/ The tax incentives specified in this Clause shall not be applied to cases of expanded investment as a result of the merger or acquisition of enterprises or investment projects in operation.

6. An expanded investment project will be entitled to the incentives specified at Point b, Clause 5 of this Article if satisfying one of the following criteria:

a/ After the project completely disburses the additionally registered capital amount, the historical costs of fixed assets reach the Government-set minimum level corresponding to the cases of expanded investment projects in sectors or trades eligible for CIT incentives or expanded investment projects implemented in geographical areas eligible for CIT incentives;

b/ After the project completely disburses the additionally registered capital amount, the proportion of the historical costs of fixed assets equals at least 20% of the total historical costs of fixed assets before the commencement of expanded investment;

c/ After the project completely disburses the additionally registered capital amount, the designed capacity increases by at least 20% of the designed capacity before the commencement of expanded investment.

Article 15. Other cases eligible for tax exemption or reduction

1. Manufacturing, construction or transport enterprises which employ a large number of female workers will be entitled to reduction of CIT amounts equal to additional expenses for female workers.

2. Enterprises which employ a large number of ethnic minority workers will be entitled to reduction of CIT amounts equal to additional expenses for ethnic minority workers.

3. Enterprises that transfer technologies in the fields prioritized for technology transfer to organizations or individuals in geographical areas with difficult socio-economic conditions, or public non-business units providing public non-business services in geographical areas with difficult socio-economic conditions will be entitled to a 50% reduction of the CIT amounts calculated on income from technology transfer or income from the provision of public non-business services in geographical areas with difficult socio-economic conditions.

4. Enterprises specified in Clauses 2 and 3, Article 10 of this Law which are established from business households will be entitled to CIT exemption for 2 consecutive years after generating taxable income.

5. Public science and technology organizations and public higher education institutions operating for not-for-profit purposes will be entitled to tax exemption in accordance with the Government’s regulations.

6. The Government shall detail this Article.

Article 16. Carryforward of losses

1. Loss-suffering enterprises may carry forward their losses to the subsequent year; such losses shall be deducted from taxable income. The loss carryforward period must not exceed 5 consecutive years, counting from the year following the year the losses arise.

2. Enterprises suffering losses from the transfer of mineral exploration and exploitation projects; transfer of the right to participate in mineral exploration, exploitation and processing projects; or transfer of the right to explore, exploit and process minerals may carry forward losses to subsequent years against the taxable income of such activities. The loss carryforward period must comply with Clause 1 of this Article.

3. The Government shall detail this Article.

Article 17. Deductions for setting up scientific and technological development funds

1. Enterprises, organizations, and non-business units established in accordance with Vietnam’s law may deduct up to 20% of their annual taxed income for setting up scientific and technological development funds.

2. Within 5 years after being set up under Clause 1 of this Article, if a scientific and technological development fund is not used, has been used by below 70% or has been used for improper purposes, the concerned enterprise, organization or non-business unit shall remit into the state budget the CIT amount calculated on the income already deducted for setting up the fund but not used or used for improper purposes and the interest on that CIT amount.

The CIT rate used for calculating the to-be-recovered tax amount is the tax rate applicable to the enterprise, organization or non-business unit during the period the fund is set up. 

The interest rate for calculating the interest on the to-be-recovered tax amount calculated on the unused fund amount is the interest rate for treasury bonds of 5-year or 10-year term (in case treasury bonds of a 5-year term are unavailable) that are issued closest to the time of recovery and the interest calculation period is 2 years.

The interest rate for calculating the interest on the to-be-recovered tax amount calculated on the fund amount used for improper purposes is the late-payment interest rate specified in the Law on Tax Administration and the interest calculation period is from the time the fund is set up to the time of recovery.

3. Enterprises, organizations and public non-business units may not account expenses covered by their scientific and technological development funds as deductible expenses upon the determination of taxable income in a tax period.

4. Scientific and technological development funds shall be used in accordance with the law on science, technology and innovation.

5. In case an enterprise in operation undergoes changes due to the merger, consolidation, division, splitting, ownership transfer or enterprise transformation, the enterprise established as a result of the merger, consolidation, division, splitting, ownership transfer or enterprise transformation may take over, and bear responsibility for the management and use of, the scientific and technological development fund of the former enterprise.

Article 18. Conditions for application of tax incentives

1. The CIT incentives specified in Articles 13, 14, and 15 of this Law shall be applied to enterprises which implement regulations on accounting, invoices and documents and pay tax by the declaration method.

CIT incentives applicable to new investment projects (including also the investment projects specified at Point g, Clause 2, Article 12 of this Law) as referred to in Articles 13 and 14 of this Law shall not be applied to cases of the merger, consolidation, division, splitting, ownership transfer and enterprise transformation and other cases specified by the Government.

2. Enterprises shall separately account income from production and business activities eligible for tax incentives specified in Articles 4, 13, 14 and 15 of this Law from income from production and business activities ineligible for tax incentives; if separate accounting is impossible, income from production and business activities eligible for tax incentives shall be determined based on the ratio of turnover or expenses of production and business activities eligible for tax incentives to the total turnover  or total expenses of enterprises.

3. The tax rates of 15% and 17% specified in Clauses 2 and 3, Article 10 of this Law and the tax incentives provided in Articles 4, 13, 14 and 15 of this Law shall not be applied to:

a/ Income from the transfer of capital or transfer of the capital-contributing rights; income from the transfer of real estate, except income from investment in the construction of social housing  specified at Point s, Clause 2, Article 12 of this Law; income from the transfer of investment projects (except the transfer of mineral processing projects), transfer of the right to participate in investment projects, or transfer of the right to explore, exploit and process minerals; and income from production and business activities carried out outside Vietnam;

b/ Income from activities of prospecting, exploring and exploiting oil and gas and other precious and rare natural resources, and income from mineral exploration and exploitation activities;

c/ Income from the production of and trading in online video games; and income from the production of and trading in goods and services subject to excise tax in accordance with the Law on Excise Tax, except projects to manufacture or assemble automobiles, airplanes, helicopters, gliders, yachts, and oil refinery and petrochemicals;

d/ Specific cases as specified by the Government.

4. The tax rates of 15% and 17% specified in Clauses 2 and 3, Article 10 of this Law shall not be applied to enterprises being subsidiaries or companies with association relationship where the enterprises in association relationship fail to meet the conditions for application of the tax rates specified in Clauses 2 and 3, Article 10 of this Law.

5. If an enterprise fails to meet the conditions for application of tax incentives, the competent agency shall retroactively collect tax and sanction violations in accordance with law.

6. The Government shall detail Clause 5 of this Article. The Ministry of Finance shall specify the procedures and dossiers for application of tax incentives specified in Articles 4, 13, 14 and 15 of this Law.

Chapter IV

IMPLEMENTATION PROVISIONS

Article 19. Effect

1. This Law takes effect on October 1, 2025, and shall apply from the 2025 CIT period.

2. Law No. 14/2008/QH12 on Corporate Income Tax, which has a number of articles amended and supplemented under Law No. 32/2013/QH13, Law No. 71/2014/QH13, Law No. 61/2020/QH14, Law No. 12/2022/QH15, and Law No. 15/2023/QH15, ceases to be effective on the effective date of this Law.

3. In case the Organization for Economic Cooperation and Development or the United Nations has more favorable provisions or instructions on the taxing right for income source countries, including Vietnam, the Government shall be assigned to provide specific regulations for implementation.

Article 20. Transitional provisions

1. For an enterprise having an investment project eligible for CIT incentives under the law on corporate income tax as of the time the enterprise is issued the license or investment certificate or as of the time the enterprise is licensed to make investment under the law on investment, in case the law on corporate income tax is amended and supplemented and the enterprise meets the conditions for eligibility for tax incentives under the amended or supplemented law, the enterprise may choose to enjoy incentives on the tax rate and the tax exemption or reduction period in accordance with law at the time the enterprise is issued the license or investment certificate or at the time the enterprise is licensed to make investment or in accordance with the amended or supplemented law for the remaining period.

2. In case an enterprise has an investment project ineligible for incentives provided in legal documents on CIT before the effective date of this Law but eligible for incentives under this Law, the enterprise will be entitled to the incentives specified in this Law for the remaining period, counting from the 2025 tax period.

This Law was passed on June 14, 2025, by the 15^th National Assembly of the Socialist Republic of Vietnam at its 9^th session.-

Chairman of the National Assembly
TRAN THANH MAN