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| NATIONAL ASSEMBLY _______ Law No. 67/2025/QH15 | SOCIALIST REPUBLIC OF VIETNAM INDEPENDENCE – FREEDOM – HAPPINESS _________________ |
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Pursuant to the Constitution of the Socialist Republic of Vietnam;
The National Assembly promulgates the Law on Corporate Income Tax.
This Law provides for taxpayers, taxable incomes, tax-exempt incomes, tax calculation bases, tax calculation methods and enterprise income tax incentives.
1. Corporate income tax payers are organizations engaged in the production and trading of goods and services earning taxable incomes under the provisions of this Law (hereinafter referred to as enterprises), including:
a) The enterprise is established in accordance with the provisions of Vietnamese law;
b) An enterprise established under the provisions of foreign law (hereinafter referred to as a foreign enterprise) with or without a permanent establishment in Vietnam;
c) Cooperatives and unions of cooperatives established in accordance with the Law on Cooperatives;
d) Non-business units established in accordance with the provisions of Vietnamese law; dd) Other organizations engaged in production and business activities earning incomes.
2. Enterprises with taxable incomes specified in Article 3 of this Law must pay enterprise income tax as follows:
a) Enterprises established under the provisions of Vietnamese law shall pay tax on taxable incomes arising in Vietnam and taxable incomes arising outside Vietnam; b) Foreign enterprises with permanent establishments in Vietnam shall pay tax on taxable incomes arising in Vietnam and taxable incomes arising outside Vietnam related to the operation of such permanent establishments;
c) Foreign enterprises with permanent establishments in Vietnam pay tax on taxable incomes arising in Vietnam but such incomes are not related to the operation of permanent establishments;
d) Foreign enterprises that do not have permanent establishments in Vietnam, including e-commerce businesses, businesses based on digital platforms, pay tax on taxable incomes arising in Vietnam.
3. Permanent establishment of a foreign enterprise means a production and/or business establishment through which a foreign enterprise conducts part or all of its production and business activities in Vietnam, including:
a) Branches, executive offices, factories, workshops, means of transport, oil fields, gas fields, mines or other natural resource exploitation locations in Vietnam;
b) Construction location, construction, installation and assembly works;
c) Establishments providing services, including consultancy services through employees or other organizations and individuals;
d) Agents for foreign enterprises;
dd) A representative in Vietnam in case of being a representative competent to sign contracts in the name of a foreign enterprise or a representative not competent to sign contracts in the name of a foreign enterprise but regularly delivering goods or providing services in Vietnam;
e) E-commerce platforms and digital platforms through which foreign enterprises provide goods and services in Vietnam.
4. The Government shall detail this Article.
1. Incomes subject to enterprise income tax include incomes from production and trading of goods and services and other incomes specified in Clause 2 of this Article.
2. Other incomes include:
a) Incomes from capital transfer, transfer of capital contribution rights, transfer of securities;
b) Incomes from real estate transfer, except for incomes from real estate transfer of real estate enterprises;
c) Incomes from the transfer of investment projects, the transfer of the right to participate in investment projects, the transfer of the right to mineral exploration, exploitation and processing;
d) Incomes from transfer, lease or liquidation of assets, including valuable papers, except for real estate;
dd) Incomes from the right to use and ownership of assets, including incomes from intellectual property rights and technology transfer;
e) Income from interest on deposits, capital loans, and sale of foreign currencies, except for income from credit activities of credit institutions;
g) The amount deducted in advance from expenses but not used up or not used up but not used up but not accounted for the reduction of deductible expenses; bad debts that have been written off are now recoverable; liabilities whose creditors cannot be identified; the income from business of previous years was omitted and now discovered;
h) The difference between the collection of fines and compensations due to violations of economic contracts or bonuses due to the good performance of contractual commitments;
i) Donations and donations in cash or in kind received;
k) The difference due to the revaluation of assets in accordance with law for capital contribution or transfer upon merger, consolidation, division, separation, transformation of owners or transformation of types of enterprises;
l) Incomes from business cooperation contracts;
m) Incomes from overseas production and business activities;
n) Incomes of public non-business units for activities of leasing public property;
o) Other incomes, except for tax-exempt incomes specified in Article 4 of this Law.
3. Taxable incomes arising in Vietnam of foreign enterprises specified at Points c and d, Clause 2, Article 2 of this Law are incomes received originating from Vietnam, regardless of the place of conducting business.
4. Foreign-invested Vietnamese enterprises that generate incomes from overseas production and business activities in the tax period may deduct the payable enterprise income tax amounts according to regulations of the investment-receiving countries into the payable enterprise income tax amounts in Vietnam. but must not exceed the amount of corporate income tax calculated in accordance with the law on corporate income tax of Vietnam.
5. If an enterprise has to pay additional enterprise income tax on aggregate minimum taxable income (IIR) as prescribed by law, the additional payable enterprise income tax shall be deducted from the payable enterprise income tax amount in Vietnam in accordance with the provisions of this Law.
6. The Government shall detail this Article.
1. Incomes from fishing activities; incomes of enterprises from the production of crop products, planted forests, animal husbandry, aquaculture and processing of agricultural and aquatic products (including the case of purchasing agricultural and aquatic products for processing) in areas with extremely difficult socio-economic conditions; incomes of cooperatives and cooperative unions from the production of crop products, planted forests, animal husbandry, aquaculture and processing of agricultural and aquatic products (including the case of purchasing agricultural and aquatic products for processing) and salt production.
2. Incomes of cooperatives and unions of cooperatives operating in the fields of agriculture, forestry, fishery and salt industry in areas with difficult socio-economic conditions or in areas with extremely difficult socio-economic conditions.
3. Incomes from the provision of technical services directly in service of agriculture.
4. Incomes from the performance of contracts on scientific research, technological development, innovation and digital transformation; income from the sale of products made from new technologies applied for the first time in Vietnam; incomes from the sale of products manufactured on a trial basis during the trial production period, including controlled trial production as prescribed by law. Income under this Clause shall be exempt from tax for a maximum of 03 years.
5. Incomes from the production and trading of goods and services of enterprises with 30% or more of the average number of employees in a year are disabled people, people after drug detoxification, people infected with viruses causing human acquired immunodeficiency syndrome (HIV/AIDS) and have an average number of employees in a year of 20 or more people, excluding enterprises operating in the field of finance and real estate business.
6. Incomes from vocational education and vocational training activities reserved exclusively for ethnic minorities, disabled persons, children in special circumstances and social evils.
7. Incomes shall be divided from capital contribution, purchase of shares, joint ventures or associations with domestic enterprises after payment of enterprise income tax in accordance with the provisions of this Law, including cases in which the recipients of capital contribution, stock issuance, joint ventures or associations are entitled to enterprise income tax incentives.
8. Grants received for use in educational, cultural, artistic, charitable, humanitarian and other social activities in Vietnam; the grant received from enterprises without associated relations, domestic and foreign organizations and individuals to be used for scientific research, technological development and innovation, and digital transformation; direct support from the state budget and from the Investment Support Fund established by the Government; the State's compensation in accordance with law.
In case the donation received in this Clause is used for improper purposes, it shall be subject to tax arrears and sanctioned for violations in accordance with law.
9. The difference due to the revaluation of assets in accordance with law for equitization or rearrangement of enterprises with 100% charter capital held by the State.
10. Incomes from the transfer of emission reduction certificates or carbon credits for the first time after issuance by enterprises granted emission reduction certificates or carbon credits; income from green bond interest; income from the transfer of green bonds for the first time after issuance.
11. Incomes (including interest on bank deposits, government bonds, treasury bills) from the performance of tasks assigned by the State in the following cases:
a) Incomes of the Vietnam Development Bank in development investment credit activities and export credit;
b) Incomes of the Bank for Social Policies from credit activities for the poor and other policy beneficiaries;
c) Incomes of single-member limited liability companies managing assets of Vietnamese credit institutions;
d) Incomes from revenue-generating activities of state financial funds and other State funds and organizations operating not for profit objectives shall be prescribed or decided by the Government or the Prime Minister.
12. The undivided incomes of establishments undergoing socialization in the fields of education and training, health care and other socialization left for investment in the development of such establishments shall meet the minimum rate prescribed by the Government; the income from the formation of the undivided common fund and undivided common assets of cooperatives and cooperative unions established and operating in accordance with the law on cooperatives.
13. Incomes from technology transfer in the domains prioritized for technology transfer to organizations and individuals in areas with extremely difficult socio-economic conditions.
14. Incomes 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 public non-business services funded by the state budget promulgated by competent agencies;
b) Public non-business services that the State must support and ensure operating expenses because the cost of providing services has not been fully included in the service price;
c) Public non-business services in areas with extremely difficult socio-economic conditions.
15. The Government shall detail this Article.
1. The enterprise income tax period shall be determined according to the calendar year or fiscal year selected by the enterprise, except for the case specified in Clause 2 of this Article. In case the enterprise chooses a fiscal year different from the calendar year, it shall notify the directly managing tax authority before implementation.
2. The tax period for enterprises specified at Points c and d, Clause 2, Article 2 of this Law shall comply with the law on tax administration.
The basis for tax calculation is taxable income and tax rate.
1. Taxable income in a tax period is determined as follows:
Taxable income = Assessable income - (Exempt income + Carried-forward losses as stipulated)
2. Taxable incomes specified in Clause 1 of this Article are determined as follows:
| Taxable income | = Revenue - | Deductible expenses | + | Other incomes (including incomes received outside Vietnam) |
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3. If an enterprise has many production and business activities in a tax period, the taxable income from production and business activities is the total income of all production and business activities. In case of losses in production and business activities, the losses shall be offset against the taxable incomes of production and business activities with incomes selected by enterprises (except for incomes from real estate transfers, investment project transfers, transfer of the right to participate in non-clearing investment projects with incomes from production and business activities that are enjoying tax incentives). The remaining income after clearing shall be subject to the corporate income tax rate of production and business activities that still have income.
4. Taxable incomes from the transfer of investment projects on mineral exploration, exploitation and processing; transfer of the right to participate in investment projects on mineral exploration, exploitation and processing; the transfer of the right to explore, exploit and process minerals must be determined separately for tax declaration and payment, and losses and profits from production and business activities in the tax period must not be offset.
1. Turnover for calculation of taxable income means all proceeds from sale of goods, processing and provision of services, including price subsidies, surcharges and surcharges to which enterprises are entitled, regardless of whether money has been collected or not.
2. The Government shall detail this Article.
1. Except for the expenses specified in Clause 2 of this Article, an enterprise may deduct expenses when determining taxable income if it fully satisfies the following conditions:
a) Actual expenses incurred related to production and business activities of the enterprise, including additional expenses deducted as a percentage of actual expenses incurred in the tax period related to the enterprise's research and development activities;
b) Other actual expenses incurred, including:
b1) Expenditures for the performance of national defense and security education, training and operation of the militia and self-defense forces and other defense and security tasks as prescribed by law;
b2) Expenditures on support in service of activities of Party organizations and socio-political organizations in enterprises;
b3) Expenses for vocational education and vocational training activities for employees as prescribed by law;
b4) Actual expenditures for HIV/AIDS prevention and control activities at the workplace of the enterprise;
b5) Funding for education, health and culture; grants for prevention, control and overcoming of consequences of natural disasters and epidemics, construction of great solidarity houses, houses of gratitude, houses for policy beneficiaries in accordance with law; grants prescribed by the Government and the Prime Minister for localities in areas with extremely difficult socio-economic conditions; funding for scientific research, technology development and innovation, digital transformation;
b6) Expenditures on scientific research, technological development, innovation and digital transformation;
b7) The value of losses caused by natural disasters, epidemics and other force majeure cases shall not be compensated;
b8) Actual expenses for persons seconded to participate in the administration, administration and control of credit institutions under special control and commercial banks that are compulsorily transferred in accordance with the Law on Credit Institutions;
b9) A number of expenditures in service of production and business of the enterprise which do not correspond to the revenue generated in the period as prescribed by the Government;
b10) A number of expenses to support the construction of public works, and at the same time serve the production and business activities of enterprises;
b11) Expenses related to the reduction of greenhouse gas emissions in order to neutralize carbon and net zero, reduce environmental pollution, and at the same time related to the production and business activities of enterprises;
b12) A number of contributions to funds established under the Prime Minister's decision and the Government's regulations;
c) Expenditures with sufficient non-cash invoices and vouchers as prescribed by law, except for special cases prescribed by the Government.
2. Expenses not eligible for deduction when determining taxable incomes include:
a) The expenditure does not fully meet the conditions specified in Clause 1 of this Article;
b) A fine for administrative violations;
c) Expenses offset by other funding sources;
d) Expenditures in excess prescribed by the Government for: business management expenses allocated by foreign enterprises to permanent establishments in Vietnam; expenses for hiring and managing prize-winning electronic game business and casino business; payment of loan interest of enterprises with related-party transactions; expenditures of a direct welfare nature for employees; contributions to participate in additional pension insurance in accordance with the Law on Social Insurance or funds of social security nature, purchase of voluntary pension insurance, life insurance for employees;
dd) The amount of appropriation is not in accordance with or in excess of the provisions of the law on provisions;
e) The depreciation of fixed assets is not in accordance with or exceeds the level prescribed by law;
g) The advance deduction from expenses is not in accordance with law;
h) Salaries and remunerations of owners of private enterprises and owners of single-member limited liability companies owned by individuals; remuneration paid to the founder of the enterprise who does not directly participate in production and business administration; salaries, wages and other expenditure accounts to pay employees but in fact do not pay or do not have invoices and vouchers as prescribed by law;
i) The loan interest payment corresponding to the missing charter capital; interest on loans in the investment process has been recorded in the investment value; loan interest for the implementation of oil and gas prospection, exploration and exploitation contracts; the interest payment on production and business loans of non-credit institutions in excess of the provisions of the Civil Code;
k) The amount of expenses allowed to be recovered in excess of the rate specified in the approved petroleum contract; in case the petroleum contract does not provide for the cost recovery rate, the cost in excess of the level prescribed by the Government shall not be included in the deductible expenses;
l) The deducted input value-added tax portion; value-added tax paid by the deduction method; input value-added tax on the value of passenger cars with 09 seats or less in excess of the level prescribed by the Government; corporate income tax; taxes, charges, fees and other revenues shall not be included in expenses as prescribed by law and late payment interest in accordance with the law on tax administration.
The value-added tax paid by the deduction method specified at this Point does not include the value-added tax portion of input goods and services directly related to the production and business of the enterprise which has not been fully deducted but is not eligible for tax refund.
The input value-added tax amount, when it has been included in the deductible expenses, shall not be deducted from the output value-added tax amount;
m) Expenditures that do not correspond to taxable turnover, except for the expenditures specified at Point b, Clause 1 of this Article; expenditures that do not meet the expenditure conditions and expenditure contents as prescribed by specialized laws;
n) The donation, except for the donor specified at Sub-Point b5, Point b, Clause 1 of this Article;
o) Expenditures on capital construction investment in the investment stage for the formation of fixed assets; expenses directly related to the increase or decrease of the enterprise's equity;
p) Expenses for business activities: banking, insurance, lottery, securities, BT, BOT, BTO contracts that are not in accordance with or exceed the level prescribed by law;
q) Other expenses.
3. The Government shall detail this Article, including the level of additional expenditures, conditions, time and scope applicable to expenditures for research and development activities of enterprises specified at Point a, Clause 1 of this Article.
The Ministry of Finance shall prescribe the dossier of the expenditure to be included in the deductible expenses specified at Points b and c, Clause 1 of this Article.
1. The enterprise income tax rate is 20%, except for the cases specified in Clauses 2, 3 and 4 of this Article and the subjects eligible for tax rate incentives specified in Article 13 of this Law.
2. The tax rate of 15% applies to enterprises with a total annual turnover of not more than VND 3 billion.
3. The tax rate of 17% applies to enterprises with a total annual turnover of between over VND 3 billion and not exceeding VND 50 billion.
The turnover used as a basis for determining that an enterprise is eligible for the tax rate of 15% and 17% specified in Clauses 2 and 3 of this Article is the total turnover of the preceding enterprise income tax period. The determination of total revenue as a basis for application shall comply with the Government's regulations.
4. The corporate income tax rate for a number of other cases is prescribed as follows:
a) For oil and gas prospection, exploration and exploitation activities, between 25% and 50%. Based on the location, conditions of exploitation and field reserves, the Prime Minister shall decide on specific tax rates suitable to each petroleum contract;
b) For exploration and exploitation of rare and precious resources (including platinum, gold, silver, tin, wonfram, antimoan, precious stones, rare earths and other precious and rare resources as prescribed by law), 50%. In case mines have 70% or more of the allocated area in areas with extremely difficult socio-economic conditions, the tax rate is 40%.
1. The payable enterprise income tax amount in a tax period is calculated by multiplying taxable income by the tax rate, except for the case specified in Clause 2 of this Article.
2. The Government shall prescribe the payable enterprise income tax amount calculated as a percentage of turnover in the following cases:
a) Enterprises specified at Points c and d, Clause 2, Article 2 of this Law; subjects performing the obligation to declare and pay tax, time and method of determining turnover for calculating taxable income arising in Vietnam;
b) An enterprise with a total annual turnover of not more than VND 3 billion specified in Clause 2, Article 10 of this Law in case the turnover is determined but the expenses and incomes of production and business activities cannot be determined;
c) Cooperatives, cooperative unions, non-business units and other organizations specified at Points c, d and dd, Clause 1, Article 2 of this Law that produce and trade in goods and services with incomes subject to enterprise income tax (except for tax-exempt incomes specified in Article 4 of this Law) which these units can account revenue but cannot determine expenses and incomes of production and business activities.
1. Enterprises are entitled to enterprise income tax incentives according to the business lines eligible for enterprise income tax incentives and geographical areas eligible for enterprise income tax incentives specified in this Article. The level of enterprise income tax incentives shall comply with the provisions of Articles 13 and 14 of this Law.
In case other laws provide for enterprise income tax incentives different from the provisions of this Law, the provisions of this Law shall apply, except for the Capital Law and resolutions prescribing special and specific mechanisms and policies of the National Assembly.
In the same period, if an enterprise is entitled to many different tax incentives under the provisions of this Law for the same income, the enterprise may choose to apply the most advantageous tax incentive level.
2. Sectors and trades eligible for enterprise income tax incentives include:
a) Application of high technologies and venture capital for hi-tech development on the list of hi-tech projects prioritized for development investment under the Law on High Technology; apply strategic technologies in accordance with law; incubation of high-tech enterprises, incubation of high-tech enterprises; invest in the construction and operation of high-tech incubators and high-tech enterprise incubators;
b) Manufacturing software products; produce cyber information security products and provide cyber information security services to ensure the conditions prescribed by the law on cyber information security; production of products, provision of key digital technology services, production of electronic equipment in accordance with the law on digital technology industry; research and development, design, production, packaging and testing of semiconductor chip products; building an artificial intelligence data center;
c) Producing supporting industry products on the list of supporting industry products prioritized for development prescribed by the Government, satisfying one of the following criteria:
c1) Supporting industrial products for high technology in accordance with the Law on High Technology;
c2) Supporting industrial products for the production of products in the textile - garment, leather - footwear, electronics - informatics (including semiconductor design and production), automobile production and assembly, mechanical engineering and manufacturing up to the effective date of this Law which cannot be produced domestically or have been produced but must meet the technical standards of the European Union or equivalent (if any) as prescribed by the Minister of Industry and Trade;
d) Producing renewable energy, clean energy and energy from waste disposal; environmental protection; production of composite materials, light building materials, rare and precious materials; production of national defense and security and production of industrial mobilization products in accordance with the law on defense and security industry and industrial mobilization; production of key chemical industry products and key mechanical products in accordance with law;
dd) Investment in the development of water plants, power plants, water supply and drainage systems, bridges, roads, railways, airports, seaports, river ports, airports, railway stations and other particularly important infrastructure works decided by the Prime Minister;
e) Hi-tech enterprises and agricultural enterprises applying hi-tech in accordance with the Law on Hi-Tech; science and technology enterprises in accordance with the Law on Science, Technology and Innovation;
g) Investment projects in the field of production that satisfy the following conditions:
g1) Having an investment capital of at least VND 12,000 billion and disbursing the total registered investment capital for no more than 05 years from the date of investment permission in accordance with the law on investment;
g2) Using technologies that meet the requirements prescribed by the Minister of Science and Technology;
h) Investment projects eligible for special investment incentives and supports specified in Clause 2, Article 20 of the Law on Investment. The Government shall detail the time for disbursement of the total registered investment capital of the projects specified at this Point;
i) Planting, caring for and protecting forests; production, propagation and breeding of plant and livestock varieties; investment in post-harvest preservation of agricultural products, preservation of agricultural, aquatic and food products; producing, exploiting and refining salt, except for the production of salt specified in Clause 1, Article 4 of this Law;
k) Cultivation of forest products;
l) Products of crops, forests, animal husbandry, aquaculture and processing of agricultural and aquatic products.
Incomes from processing agricultural and aquatic products specified at this Point must satisfy the conditions specified in Clause 1, Article 4 of this Law;
m) Production of high-grade steel; production of energy-saving products; production of machinery and equipment in service of agricultural, forestry, fishery and salt production; production of irrigation equipment; production of livestock, poultry and aquatic feed;
n) Manufacturing and assembling automobiles; production of other digital technology products;
o) Investment in business of technical establishments to support small and medium-sized enterprises, small and medium-sized enterprise incubators; invest in business co-working areas to support innovative start-ups of small and medium-sized enterprises in accordance with the Law on Support for Small and Medium Enterprises;
p) People's credit funds, microfinance institutions, cooperative banks;
q) Cooperatives and unions of cooperatives operating in the fields of agriculture, forestry, fishery and salt;
r) Socialization in the fields of education and training, vocational training, health, culture, sports and environment according to the list of types, scale criteria and standards prescribed by the Prime Minister; judicial expertise;
s) Investment in the construction of social houses for sale, lease or lease-purchase for beneficiaries of social housing support policies in accordance with the Housing Law;
t) Publication in accordance with the Publication Law;
u) Press (including advertisements in newspapers) in accordance with the Press Law.
3. Areas of enterprise income tax incentives prescribed by the Government, including:
a) Areas with extremely difficult socio-economic conditions;
b) Areas with difficult socio-economic conditions;
c) Economic zones, hi-tech parks, hi-tech agricultural zones, and concentrated digital technology parks.
4. The Government shall prescribe the application of tax incentives in the following cases:
a) In case of application of tax incentives according to geographical criteria;
b) In case of tax incentives in the fields of agriculture, forestry, fishery and salt;
c) In case there is turnover in the first tax period or income from investment projects of enterprises in the first tax period (including new investment projects, expansion investment projects, hi-tech enterprises, hi-tech agricultural enterprises, science and technology enterprises) that have generated revenue and income for less than 12 months to enjoy tax incentives.
5. Enterprises established or enterprises that have investment projects from mergers, mergers, divisions, separations, transformation of owners, or transformation of enterprise types shall have to fulfill the obligation to pay enterprise income tax (including fines, if any), and at the same time inherit enterprise income tax incentives (including losses that have not yet been carried forward) of enterprises enterprises or investment projects before merger, consolidation, division, separation or transformation if they continue to meet the conditions for corporate income tax incentives and conditions for carrying forward losses as prescribed by law.
1. The tax rate of 10% for 15 years shall be applied to:
a) Incomes of enterprises from the implementation of new investment projects specified at Points a, b, c, d and dd, Clause 2, Article 12 of this Law; incomes of enterprises specified at Point e, Clause 2, Article 12 of this Law;
b) Incomes of enterprises from the implementation of investment projects specified at Points g and h, Clause 2, Article 12 of this Law;
c) Incomes of enterprises from the implementation of new investment projects in the localities specified at Point a, Clause 3, Article 12 of this Law;
d) Incomes of enterprises from the implementation of new investment projects in hi-tech parks, hi-tech agricultural parks and concentrated digital technology parks; new investment projects in economic zones located in tax-eligible areas specified at Points a and b, Clause 3, Article 12 of this Law. In case an investment project is located in an economic zone where the project location is located in both the geographical area of tax incentives and the geographical area not in the geographical area of tax incentives, the determination of tax incentives of the project shall be prescribed by the Government.
2. The tax rate of 10% shall be applied to:
a) Incomes of enterprises from activities in the sectors and trades specified at Points k and 1, Clause 2, Article 12 of this Law in the tax incentives specified at Point b, Clause 3, Article 12 of this Law;
b) Incomes of enterprises from activities in the sectors and trades specified at Points i, r and s, Clause 2, Article 12 of this Law;
c) Incomes of publishing houses from activities in the branches and trades specified at Point t, Clause 2, Article 12 of this Law;
d) The incomes of cooperatives and unions of cooperatives specified at Point q, Clause 2, Article 12 of this Law are not in the localities specified in Clause 3, Article 12 of this Law;
dd) Incomes of press agencies in the lines specified at Point u, Clause 2, Article 12 of this Law.
3. The tax rate of 15% shall be applied to incomes of enterprises from activities in the business lines specified at Point 1, Clause 2, Article 12 of this Law other than those specified in Clause 3, Article 12 of this Law.
4. To apply the tax rate of 17% for a period of 10 years for:
a) New investment projects in the preferential sectors and trades specified at Points m, n and o, Clause 2, Article 12 of this Law;
b) New investment projects implemented in the localities specified at Point b, Clause 3, Article 12 of this Law;
c) New investment projects in economic zones 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 the incomes of enterprises at Point p, Clause 2, Article 12 of this Law.
6. The extension of time and application of preferential tax rates are prescribed as follows:
a) The Prime Minister shall decide on the extension of the application of preferential tax rates for a maximum of 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, with a minimum investment capital of VND 6,000 billion, having a great socio-economic impact, need to be specially encouraged;
a2) The investment project specified at Point g, Clause 2, Article 12 of this Law satisfies one of the following criteria:
- Producing globally competitive products and goods, with a turnover of over VND 20,000 billion/year at the latest after 05 years from the date of revenue from the investment project;
- Regular employment of more than 6,000 laborers determined in accordance with the labor law;
- Investment projects in the field of economic and technical infrastructure, including: Investment in development of water plants, power plants, water supply and drainage systems, bridges, roads, railways, airports, seaports, river ports, airports, railway stations, new energy, clean energy, energy-saving industries, etc petrochemical refining project;
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 tax rates reduced by not more than 50% of the tax rates specified in Clause 1 of this Article; the duration of application of preferential tax rates shall not exceed 1.5 times the duration of application of preferential tax rates specified in Clause 1 of this Article and may be extended for no more than 15 years but must not exceed the duration of the investment project.
7. The period of application of preferential tax rates to incomes from the execution of new investment projects of enterprises specified in this Article (including projects specified at Point g, Clause 2, Article 12 of this Law) shall be counted from the first year of the enterprise's new investment project with turnover.
In case an enterprise is granted a certificate of hi-tech enterprise, a certificate of a hi-tech agricultural enterprise, a certificate of a science and technology enterprise, a certificate of a hi-tech application project, or a certificate of incentives for a project on production of supporting industrial products after the time of revenue generation, the tax rate shall be applied incentives are calculated from the year of issuance of the certificate or certificate of incentives.
1. Tax exemption for up to 04 years and 50% reduction of payable tax amount for not more than 09 subsequent years for:
a) Incomes of enterprises specified in Clause 1, Article 13 of this Law;
b) The income of the enterprise specified at Point r, Clause 2, Article 12 of this Law is in the locality specified at Points a and b, Clause 3, Article 12 of this Law; in case of not falling into the geographical areas specified at Points a and b, Clause 3, Article 12 of this Law, they shall be exempt from tax for a maximum of 04 years and reduced by 50% of the payable tax amount for a maximum of 05 subsequent years.
2. Tax exemption for up to 02 years and 50% reduction of payable tax amount for up to 04 subsequent years for incomes of enterprises 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 to extend the tax exemption or reduction duration by not exceeding 1.5 times the tax exemption or reduction duration specified in Clause 1 of this Article.
4. The tax exemption or reduction period is calculated from the first year of taxable income from the investment project, in case there is no taxable income in the first 03 years from the first year of revenue from the project, the tax exemption or reduction period is calculated from the 4th year.
In case an enterprise is granted a certificate of a hi-tech application project, a certificate of hi-tech enterprise, a certificate of a hi-tech agricultural enterprise, a certificate of science and technology enterprise, or a certificate of incentives for a project on production of supporting industrial products after the time of income generation, the tax exemption period tax reduction shall be calculated from the year of issuance of the certificate or certificate of incentives. In case in the year of issuance of the Certificate or Certificate of Preferences but there is no income, the tax exemption or reduction period shall be counted from the first year of income, if in the first 03 years from the year of issuance of the Certificate or Certificate of Preferences the enterprise has no taxable income, the tax exemption period, tax reduction calculated from the 4th year from the year of issuance of certificates and certificates of incentives.
5. Tax incentives for expansion investment projects:
a) Enterprises that have investment projects in operation to expand their scale, increase capacity, innovate technologies, reduce pollution or improve the environment in the branches, trades and geographical areas eligible for enterprise income tax incentives specified in Article 12 of this Law (hereinafter referred to as expansion investment) shall enjoy tax incentives according to the project in operation for the remaining time and do not have to separately account the additional income from the expansion investment and the income from the project in operation;
b) In case the operating project has expired the tax incentive period, the additional income from the expansion investment project satisfying the criteria specified in Clause 6 of this Article shall be exempt or reduced and shall not be entitled to tax rate incentives. The tax exemption or reduction period for additional income due to expansion investment is equal to the tax exemption or reduction period applicable to new investment projects in the same industry, trade lines and geographical areas eligible for corporate income tax incentives and is calculated from the year the investment project completes the registered investment capital.
Enterprises must separately account for the additional income from expansion investment to apply incentives. In case it is not possible to account separately, the income from expansion investment activities shall be determined according to the ratio of the historical cost of newly invested fixed assets put into use for production and business to the total historical cost of fixed assets of the enterprise;
c) Tax incentives specified in this Clause do not apply to cases of expansion investment due to merger or acquisition of enterprises or operating investment projects.
6. An expansion investment project eligible for the incentives specified at Point b, Clause 5 of this Article must satisfy one of the following criteria:
a) The historical cost of fixed assets will increase when the investment project completes the disbursement of the registered expansion investment capital at the minimum level prescribed by the Government, corresponding to cases where the expansion investment project is in the business lines eligible for enterprise income tax incentives, expansion investment projects implemented in areas eligible for corporate income tax incentives;
b) The proportion of the historical cost of fixed assets when the investment project completes the disbursement of the additional registered expanded investment capital shall be at least 20% of the total historical cost of fixed assets before the commencement of the expansion investment;
c) The additional design capacity shall be increased when the investment project completes the disbursement of the registered expansion investment capital of at least 20% of the design capacity before the start of the expansion investment.
1. Production, construction and transport enterprises employing a large number of female laborers shall be entitled to a reduction in enterprise income tax equal to the amount of additional expenditures for female laborers.
2. Enterprises employing many ethnic minority laborers shall be entitled to enterprise income tax reduction equal to the amount of additional expenditures for ethnic minority laborers.
3. Enterprises transferring technologies in the domains prioritized for transfer to organizations and individuals in areas with difficult socio-economic conditions and public non-business units providing public non-business services in areas with difficult socio-economic conditions are entitled to a 50% reduction in the enterprise income tax amount calculated on the income from the transfer technology and income from the provision of public non-business services in areas with difficult socio-economic conditions.
4. Enterprises specified in Clauses 2 and 3, Article 10 of this Law newly established from business households shall be exempt from enterprise income tax for 02 consecutive years from the date of taxable income.
5. Public scientific and technological organizations and public higher education institutions operating not for profit purposes shall be exempt from tax according to the Government's regulations.
6. The Government shall detail this Article.
1. Enterprises with losses may carry forward their losses to the following year; This loss amount shall be deducted from the taxable income. The period of continuous loss carry-over shall not exceed 05 years from the year following the year in which the loss is incurred.
2. Enterprises that have losses from the transfer of mineral exploration and exploitation projects; transfer of the right to participate in mineral exploration, exploitation and processing projects; the transfer of the right to mineral exploration, exploitation and processing shall carry forward the loss to the following year into the taxable income of such activities. The time limit for carrying forward losses is specified in Clause 1 of this Article.
3. The Government shall detail this Article.
1. Enterprises, organizations and non-business units established under the provisions of Vietnamese law may deduct up to 20% of their annual taxable incomes for the establishment of the science and technology development fund.
2. Within 05 years from the date of appropriation as prescribed in Clause 1 of this Article, if the science and technology development fund is not used or less than 70% of it is used or used for improper purposes, the enterprise, organization or non-business unit shall have to pay the state budget the enterprise income tax calculated on the income already set aside for the fund without using or using for improper purposes and profits arising from such enterprise income tax amount.
The corporate income tax rate used to calculate the recovered tax amount is the tax rate applied to enterprises, organizations and non-business units during the period of setting up the fund.
The interest rate for interest calculation for the recovered tax amount calculated on the unused fund is the interest rate of treasury bonds with a term of 05 years or a term of 10 years (in case there is no type of term of 05 years) issued closest to the time of recovery and the interest calculation period is 02 years.
The interest rate for calculating interest on the recovered tax amount calculated on the misused fund is the late payment interest calculation rate according to the provisions of the Law on Tax Administration and the interest calculation time is the period from the time of setting up the fund to the time of recovery.
3. Enterprises, organizations and non-business units are not allowed to account expenditures from the Science and Technology Development Fund into deductible expenses when determining taxable incomes in tax periods.
4. The science and technology development fund shall be used in accordance with the law on science, technology and innovation.
5. If an operating enterprise is changed due to merger, consolidation, division, separation, change of owner or transformation of enterprise type, the newly established enterprise or the enterprise receiving the merger from the merger, consolidation, division, separation, ownership transformation or transformation of the enterprise type shall inherit and take responsibility for the management, use the enterprise's science and technology development fund before merger, consolidation, division, separation or transformation.
1. The enterprise income tax incentives specified in Articles 13, 14 and 15 of this Law apply to enterprises that implement the regime of accounting, invoices and vouchers and pay tax by the declaration method.
Enterprise income tax incentives under new investment projects (including investment projects specified at Point g, Clause 2, Article 12 of this Law) specified in Articles 13 and 14 of this Law do not apply to cases of merger, consolidation, division, separation or transformation of owners, transformation of enterprises and other cases prescribed by the Government.
2. Enterprises must separately account incomes from production and business activities eligible for tax incentives specified in Articles 4, 13, 14 and 15 of this Law from incomes from production and business activities not eligible for tax incentives; In case it is not possible to account separately, incomes from tax-advantaged production and business activities shall be determined according to the ratio of turnover or expenses of tax-eligible production and business activities to the total turnover or total expenses of the enterprise.
3. The tax rates of 15% and 17% specified in Clauses 2 and 3, Article 10 of this Law and the provisions on tax incentives in Articles 4, 13, 14 and 15 of this Law shall not apply to:
a) Incomes from capital transfer or transfer of capital contribution rights; incomes from real estate transfer, except for incomes from investment in the construction of social houses specified at Point s, Clause 2, Article 12 of this Law; incomes from the transfer of investment projects (except for the transfer of mineral processing projects), transfer of the right to participate in investment projects, transfer of the right to mineral exploration, exploitation and processing; incomes from production and business activities outside Vietnam;
b) Incomes from the prospection, exploration and exploitation of oil and gas, other precious and rare natural resources and incomes from mineral exploration and exploitation;
c) Incomes from online production and trading of electronic games; incomes from production and trading of goods and services subject to excise tax under the Law on Excise Tax, except for projects on production and assembly of automobiles, aircraft, helicopters, gliders, yachts, petrochemical refining;
d) Special cases as prescribed by the Government.
4. The tax rates of 15% and 17% specified in Clauses 2 and 3, Article 10 of this Law shall not apply to enterprises that are subsidiaries or companies with associated relations that are not enterprises that satisfy the conditions for application of tax rates specified in Clause 2. Clause 3, Article 10 of this Law.
5. In case an enterprise fails to satisfy the conditions for tax incentives, the competent agency shall collect tax arrears and sanction violations in accordance with law.
6. The Government shall detail Clause 5 of this Article. The Ministry of Finance shall prescribe the procedures and dossiers for entitlement to tax incentives specified in Articles 4, 13, 14 and 15 of this Law.
1. This Law takes effect from October 1, 2025 and applies from the 2025 corporate income tax period.
2. The Law on Corporate Income Tax No. 14/2008/QH12 which has been amended and supplemented by a number of articles 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 shall cease to be effective from the effective date of this Law.
3. In case the Organization for Economic Development Cooperation or the United Nations has more favorable regulations and guidelines on the right to tax income source countries, including Vietnam, the Government shall assign specific regulations for implementation.
1. Enterprises having investment projects are entitled to enterprise income tax incentives in accordance with the law on enterprise income tax at the time of licensing or issuance of investment certificates or are permitted to invest in accordance with the law on investment, in case the law on corporate income tax is amended, if the enterprise satisfies the conditions for tax incentives as prescribed by the newly amended and supplemented law, the enterprise is entitled to choose to enjoy tax incentives in terms of tax rates and the tax exemption or reduction period in accordance with law at the time of licensing. issuance of investment certificates, investment permits or amendments and supplements for the remaining time as prescribed by law.
2. In case an enterprise has an investment project that is not eligible for incentives under the provisions of legal documents on corporate income tax before the effective date of this Law but is eligible for incentives under the provisions of this Law shall be entitled to the incentives prescribed in this Law for the remaining period from the date of implementation of this Law from the tax period of 2025.
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This Law was approved by the National Assembly of the Socialist Republic of Vietnam in its 15th session, 9th session on June 14, 2025.
CHAIRMAN OF THE NATIONAL ASSEMBLY
Tran Thanh Man