News
1. Decree No. 320/2025/NĐ-CP – New legal framework on Corporate Income Tax
The Government has issued Decree No. 320/2025/NĐ-CP, detailing and guiding the implementation of the Law on Corporate Income Tax (CIT).
The Decree consists of 06 chapters and 26 articles, providing specific regulations on:
Determination of taxable income
Tax bases and tax rates
Methods of tax calculation
Corporate income tax incentives
Tax exemptions and reductions
Establishment of the enterprise’s Science and Technology Development Fund
In particular, Article 3 of Decree No. 320/2025/NĐ-CP stipulates in detail the types of taxable corporate income.
2. What types of income are subject to Corporate Income Tax?
Pursuant to Article 3 of Decree No. 320/2025/NĐ-CP, taxable corporate income includes:
Income from production and business activities of goods and services
Other income arising during the tax period
3. Income from production and business activities subject to CIT
Income from registered business lines, including conditional business sectors
Income from petroleum activities and income directly related to petroleum operations, determined separately for each petroleum contract in accordance with petroleum contracts, international treaties, and specialized laws
4. Other income subject to Corporate Income Tax
Under Decree No. 320/2025/NĐ-CP, other taxable income includes:
Transfer of capital, securities, or capital contribution rights
Transfer of real estate (except for real estate trading enterprises)
Transfer of investment projects, project participation rights, and mineral exploration and exploitation rights
Income from ownership rights, usage rights of assets, intellectual property rights, and technology transfer
Income from asset leasing (excluding real estate)
Income from transfer or liquidation of assets
Income from interest on deposits, lending interest, and foreign currency trading (excluding credit institutions)
Foreign exchange gains arising during the period
Exchange rate differences from revaluation of foreign-currency-denominated liabilities at the end of the accounting period
Excluding exchange rate differences from revaluation of cash, bank deposits, cash in transit, and foreign-currency-denominated receivables
Provisions for expenses that are not used or not fully used
Bad debts previously written off but later recovered
Income of previous years that was omitted
Penalties and compensation for breach of economic contracts
Bonuses for proper performance of contractual commitments
Negative differences may be offset against other income or income from production and business activities
Gifts or donations in cash, in kind, or in services
Sponsorships, marketing support, discounts, and promotional rewards
Excluding direct support from the State budget
Income arising from relocation of production or business facilities
Differences from asset revaluation upon division, separation, merger, consolidation, or conversion of enterprises
Differences from revaluation of land-use rights contributed as capital, in accordance with detailed provisions of the Decree
Income shared based on revenue, products, or profits
Where profits are shared after tax, a representative party must be appointed to declare and pay tax
Income from overseas business activities
Income from the sale of scrap and by-products
Refunds of export and import duties
Income from capital contribution, joint ventures, and business cooperation
Other income as prescribed by law
5. Taxable income of foreign enterprises arising in Vietnam
Taxable corporate income of foreign enterprises includes:
Income from providing services or distributing goods in Vietnam
Income from e-commerce and digital platform business activities
Income from lending, royalties, and license fees
Income from transfer of capital, investment projects, capital contribution rights, and mineral exploitation rights in Vietnam
→ Regardless of where the business activities are carried out.
