📢 CORPORATE INCOME TAX 2025 – A NEW DECREE HAS BEEN ISSUED

Decree No. 320/2025/NĐ-CP provides new regulations on Corporate Income Tax (CIT) applicable from 2025.

• ⏰ Effective from: December 15, 2025

🔁 Officially replaces a series of previous Decrees

• ⛔ Decree 218/2013/NĐ-CP – Corporate Income Tax (effective from 2014)
• ⛔ Decree 12/2015/NĐ-CP – Amendments to Corporate Income Tax, Valued Add Tax, Personal Income Tax
• ⛔ Decree 91/2014/NĐ-CP – Tax Declaration & Tax Policies
• ⛔ Decree 57/2021/NĐ-CP – Supporting Industry Tax Incentives

👉 It can be confirmed that: Decree 320/2025/NĐ-CP represents a “new set of rules” for Corporate Income Tax from 2025 onwards .

🔥 Completely new points (Only available under Decree 320)

🌐 1️⃣ Foreign Businesses & the Digital Economy

E-commerce platforms and digital platforms operated by foreign businesses providing goods and services in Vietnam may be:

• 👉 Considered a Permanent Establishment (PE)
• 📍 Significantly expands the concept of Permanent Establishment (PE) in the digital era

💰 2️⃣ Capital Contribution Exceeding Registered Capital

Decree 320 clarifies the tax treatment of differences arising when a new member contributes capital at a value higher than the recorded registered capital.

• 👉 Ends long-standing debates: “Taxable income or capital surplus?”

🌱 3️⃣ Green Tax Incentives – Carbon – ESG

Corporate Income Tax (CIT) exemptions apply to:

• Income from the transfer of carbon credits
• Profits and income from green bonds (including the first transfer)
• Income from the Investment Support Fund

👉 For the first time, Corporate Income Tax (CIT) incentives are closely linked to Net Zero – ESG – sustainable development .

🧪 4️⃣ R&D Expenses Deductible Up to 200%

Enterprises are allowed to include the following as deductible expenses:

• Research and Development (R&D) expenses: deductible up to 200%
• 📌 Condition: after the deduction, the enterprise must not incur a tax loss

♻ 5️⃣ Emission reduction costs – Carbon Neutrality

Expenses related to:

• Greenhouse gas emission reduction
• Environmental protection
• Directly connected to production and business activities

👉 DEDUCTIBLE for Corporate Income Tax (CIT) purposes.

🌍 6️⃣ Global Minimum Tax (GloBE)

• Paid GloBE supplementary tax
• 👉 DEDUCTIBLE when determining Corporate Income Tax (CIT) in Vietnam

📌 Purpose: Prevent double taxation for multinational enterprises.

🔁 Notable Changes

❌ Removed Contents

• 🚫 FDI enterprises are no longer treated differently from domestic enterprises
• 🚫 The regulation on the recovery rate of oil and gas costs has been abolished
• 🚫 There is no detailed guidance on after-tax profit distribution for Business Cooperation Contracts (BCCs)
• 🚫 The requirement for hard-copy forms for the Science and Technology Development Fund has been abolished
• 🚫 Notary Offices are no longer eligible for tax incentives based on difficult or extremely difficult areas

📌 Quick Summary

• ✔ Expanding taxation of digital businesses and e-commerce platforms
• ✔ Strong incentives for R&D, ESG, and carbon-related activities
• ✔ Stricter conditions for expenses and payment requirements
• ✔ Alignment with the Global Minimum Tax regime
• ✔ Simplified procedures with stricter substance-based requirements

📣 What Do Enterprises Need to Do Right Away?

• Review the cost structure and payment methods currently applied
• Review the applicable Corporate Income Tax (CIT) incentives
• Assess the impact in cases where the enterprise is involved in R&D, ESG activities, or affiliated Companies