Law on Corporate Income Tax
VGP - The Law on Corporate Income Tax took effect from October 1, 2025, and apply from the 2025 corporate income tax period.
LAW ON CORPORATE INCOME TAX
(Law No. 67/2025/QH15)
Pursuant to the Constitution of the Socialist Republic of Viet Nam;
The National Assembly hereby promulgates the Law on Corporate Income Tax.
Chapter I
GENERAL PROVISIONS
Article 1. Scope of regulation
This Law provides for taxpayers, taxable income, tax-exempt income, tax bases, tax calculation methods, and corporate income tax incentives.
Article 2. Taxpayers
1. Corporate income taxpayers are organizations engaged in the production and business of goods and services that earn taxable income as prescribed by this Law (hereafter referred to as enterprises), including:
a) Enterprises established under the provisions of Vietnamese laws:
b) Enterprises established under the provisions of foreign law (hereafter referred to as foeign enterprises) with or without a permanent establishment in Viet Nam.
c) Cooperatives and cooperative unions established under the Law on Cooperatives;
d) Public service units established under the provisions of Vietnamese law;
dd) Other organizations engaged in production and business activities that earn income.
2. Enterprises with taxable income as specified in Article 3 of this Law shall pay corporate income tax as follows:
a) Enterprises established under the provisions of Vietnamese law shall pay tax on taxable income arising in Viet Nam and taxable income arising outside Viet Nam;
b) Foreign enterprises with a permanent establishment in Viet Nam shall pay tax on taxable income arising in Viet Nam and taxable income arising outside Viet Nam related to the operations of such permanent establishment;
c) Foreign enterprises with a permanent establishment in Viet Nam shall pay tax on taxable income arising in Viet Nam where such income is not related to the operation of the permanent establishment;
d) Foreign enterprises without a permanent establishment in Viet Nam, including e-commerce business enterprises, digital platform-based business enterprises, shall pay tax on taxable income arising in Viet Nam.
3. A permanent establishment of a foreign enterprise is a production or business establishment through which the foreign enterprise conducts part or all of its production or business in Viet Nam, including:
a) Braches, executive offices, factories, workshops, means of transportation, oil fields, gas fields, mines, or other places of extraction of natural resources in Viet Nam;
b) Construction sites, construction, installation, or assembly projects
c) Service establishments, including consulting services provided through employees or other organizations or individuals;
d) Agents for foreign enterprises;
dd) Representatives in Viet Nam in cases where the representative is authorized to sign contracts in the name of the foreign enterprise, or a representative not authorized to sign contracts in the name of the foreign enterprise but regularly delivering goods or providing services in Viet Nam;
e) E-commerce platforms, digital platforms through which foreign enterprises provide goods or services in Viet Nam.
4. The Government shall elaborate on this Article.
Article 3. Taxable income
1. Taxable corporate income includes income from production and business of goods and services, and other income specified in Clause 2 of this Article.
2. Other income includes:
a) Income from capital transfer, transfer of capital contribution rights, and transfer of securities;
b) Income from real estate transfer, excluding income from real estate transfer of real estate business enterprises;
c) Income from the transfer of investment projects, transfer of rights to participate in investment projects, and transfer of rights to explore, extract, and process minerals;
d) Income from the transfer, lease, and liquidation of assets, including valuable papers, excluding real estate;
dd) Income from asset use rights and asset ownership rights, including income from intellectual property rights and technology transfer;
e) Income from deposit interest, loan interest, and sale of foreign currencies, excluding income from credit activities of credit institutions;
g) Provisions accrued to expenses but unused or not fully used that the enterprise does not account for as reduction of deductible expenses; recovered bad debts previously written off; payables with unidentified creditors; omitted business income from previous years now discovered;
h) The difference between fines and compensation received for breaches of economic contracts or bonuses for good performance of contractual commitments;
i) Financial support and donations received in cash or in kind;
k) Differences arising from asset reevaluation in accordance with the law for capital contribution, or transfer upon merger, consolidation, division, separation, transformation of ownership, or conversion of corporate form;
l) Income from business cooperation contracts;
m) Income from overseas production and business activities;
n) Income of public service units from leasing public assets;
o) Other income, excluding tax-exempt income specified in Article 4 of this Law.
3. Taxable income arising in Viet Nam of foreign enterprises specified in Points c and d, Clause 2, Article 2 of this Law is income received from Vietnamese sources, regardless of the location where the business is conducted.
4. Vietnamese enterprises investing abroad that earn income from overseas production and business activities in a tax period shall have the corporate income tax paid under the laws of the recipient country deducted from corporate income tax payable in Viet Nam, provided that the deduction does not exceed corporate income tax calculated under Viet Nam's corporate income legislation.
5. Where an enterprise is required to pay qualified domestic minimum top-up tax under the Income Inclusion Rule (IIR) in accordance with the law, the additional corporate income tax payable shall be deducted from corporate income tax payable in Viet Nam as prescribed by this Law.
6. The Government shall elaborate on this Article.
Article 4. Tax-exempt income
1. Income from seafood harvesting activities; income of enterprises from the production of cultivated crops, planted forests, livestock breeding, aquaculture, and processing of agricultural and aquatic products (including cases of purchasing agricultural and aquatic products for processing) in areas with particularly difficult socio-economic conditions; income of cooperatives and cooperative unions from production of cultivated crops, planted forests, livestock breeding, aquaculture, processing of agricultural and aquatic products (including purchasing of agricultural and aquatic products for processing), salt production.
2. Income of cooperatives and cooperative unions operating in agriculture, forestry, fisheries, and salt production in areas with difficult socio-economic conditions or areas with particularly difficult socio-economic conditions.
3. Income from technical services directly serving agriculture.
4. Income from the performance of scientific research, technological development, innovation, and digital transformation contracts; income from the sale of products manufactured from new technologies applied for the first time in Viet Nam; income from the sale of test-production products during the test-production period, including controlled test-production in accordance with the law. Income under this Clause shall be tax-exempt for a minimum period not exceeding three years.
5. Income from production and business activities of goods and services of enterprises where disabled persons, post-rehabilitation drug addicts, persons with immunodeficiency virus (HIV/AIDS) account for at least 30 percent of the average annual workforce, and the average annual workforce is 20 persons or more, excluding enterprises operating in financial and real estate business sectors.
6. Income from vocational education and vocational training activities specifically dedicated to ethnic minorities, disabled persons, children in special circumstances, and victims of social evils.
7. Distributed profits from capital contribution, purchase of shares, joint ventures, and partnership with domestic enterprises, after corporate income tax has been paid in accordance with this Law, including cases where the capital-receiving party, share-issuing party, joint venture, or associate party enjoyr corporate income tax incentives.
8. Sponsorships received for use in educational, cultural, artistic, charitable, humanitarian, and other social activities in Viet Nam; sponsorships received from non affiliated enterprises, domestic and foreign organizations and individuals for use in scientific research, technological development, innovation, and digital transformation activities; direct support from the state budget and Investment Support Fund established by the Government; state compensation in accordance with the law.
In cases where an enterprise uses the sponsorships specified in this Clause for improper purposes, the tax shall be clawed back and administrative violations shall be penalized in accordance with the law.
9. Differences arising from asset re-evaluation in accordance with the law for equitization and restructuring of 100 percent State-owned enterprises.
10. Income from the initial transfer of certified emission reductions and carbon credits after issuance by enterprises granted emission reduction certificates or carbon credits; income from green bond interest; and income from the initial transfer of green bonds after issuance.
11. Income (including bank deposit interest, Government bond interest, and treasury bill interest) from the performance of tasks assigned by the State in the following cases:
a) Income of the Viet Nam Development Bank from development investment credit an d export credit activities;
b) Income of the Bank for Social Policies from credit lending to the poor and other policy beneficiaries;
c) Income of single-member limited liability asset management companies of Vietnamese credit institutions;
d) Income from revenue-generating activities of state financial funds and other non-profit state funds and organizations prescribed or decided by the Government or the Prime Minister.
12. Non-distributed income of socialized establishments in education and training, healthcare, and other socialized sectors retained for investment in the development of such establishments to meet the minimum ratio prescribed by the Government; non-distributed income forming common non-distributed funds and common non-distributed assets of cooperatives and cooperative unions established and operating under the law on cooperatives.
13. Income from technology transfer in the fields prioritized for technology transfer to organizations and individuals in areas with particularly difficult socio-economic conditions.
14. Income of public service units from the provision of public services, including:
a) Basic and essential public services under the list of public services funded by the state budget promulgated by competent authorities;
b) Public services where the State must support and ensure operational funding because full service provision costs have not yet been factored into service prices;
c) Public services in areas with particularly difficult socio-economic conditions.
15. The Government shall elaborate on this Article.
Article 5. Tax period
1. The corporate income tax period shall be determined according to the calendar year or the fiscal year selected by the enterprises, except as provided in Clause 2 of this Article. Where an enterprise selects a fiscal year different from the calendar year, it shall notify the directly managing tax agency prior to implementation.
2. Tax period for enterprises specified in Points c and d, Clause 2, Article 2 of this Law shall be implemented in accordance with the law on tax management.
Chapter II
TAX BASES AND TAX CALCULATION METHODS
Article 6. Tax bases
The bases for tax calculation are taxble income and the tax rate.
Article
7. Determination of taxable income
1. Taxable income in a tax period shall be determined as follows:
2. Taxable revenue specified in Clause 1 of this Article shall be determined as follows:
3. Where an enterprise conducts multiple production and business activities in a tax period, taxable income from production and business activities shall be the total income from all production and business activities. In case of a loss from certain production and business activities, such loss may be offset against taxable income of other income-generating production and business activities selected by the enterprise (except that income from real estate transfer, investment project transfer, and transfer of rights to participate in investment projects shall not be offset against income from production and business activities enjoying tax incentives). The remaining income after offsetting shall be subject to the corporate income tax rate applicable to income-generating production and business activities.
4. Taxable income from the transfer of investment projects for mineral exploration, extraction, and processing; transfer of rights to participate in projects for mineral exploration, extraction, and processing; and transfer of mineral exploration, extraction, and processing rights must be determined separately for tax declaration and payment, and shall not be offset against profit or loss from production and business activities in the tax period.
Article 8. Revenue
1. Revenue for calculating taxable income is the total sales proceeds, processing fees, and service provision fees, including price subsidies, surcharges, and extra fees earned by the enterprise, regardless of whether money is collected or not.
2. The Government shall elaborate on this Article.
Article 9. Deductible and non-deductibe expenses when determining taxable income
1. Except for expenses specified in Clause 2 of this Article, enterprises may deduct expenses when determining taxable income if all the following conditions are met:
a) Actual expenses incurred in connection with production and business activities of the enterprise, including additional deductible expenses calculated as a percentage of actual expenses in the tax period related to research and development activities of the enterprise.
b) Other actual expenses incurre, including:
b1) Expenses for performing national defense and security tasks, training, militia force activities, and serving other defense and security tasks as prescribed by law;
b2) Expenses to supporting the operations of Party organizations and socio-politic organizations within the enterprise;
b3) Expenses for vocational education and vocational training activities for employees in accordance with the law;
b4) Actual expenses for workplace HIV/AIDS prevention and control activities of the enterprise;
b5) Sponsorships for education, healthcare, and culture; sponsorships for disaster and epidemic prevention, relief, and recovery, construction of great solidarity houses, gratitude houses, and houses for policy beneficiaries as prescribed by law; sponsorships as prescribed by the Government or the Prime Minister for localities with particularly difficult socio-economic conditions; sponsorships for scientific research, technological development, innovation, and digital transformation;
b6) Expenses for scientific research, technological development, innovation, and digital transformation;
b7) Uncompensated value of losses caused by natural disasters, epidemics, and force majeure events;
b8) Actual expenses for personnel seconded to participate in the governance, operation, and control of credit institutions under special control and commercial banks subject to mandatory transfer as prescribed by the Law on credit institutions;
b9) Certain expenses serving the production and business activities of the enterprise that do not correspond revenue arising in the period as prescribed by the Government;
b10) Certain expenses supporting the construction of public works that simultaneously serve the production and business activities of the enterprise
b11) Expenses related to greenhouse gas emission reduction aiming for carbon neutrality and net zero, environmental pollution reduction, which are simultaneously related to the production and business activities of the enterprise;
b12) Certain contributions to funds established by decisions of the Prime Minister and regulations of the Government;
c) Expenses backed by sufficient invoices and non-cash payment vouchers as prescribed by the law, except for special cases specified by the Government.
2. Non-deductible expenses when determining taxable income include:
a) Expenses failing to satisfy all conditions specified in Clause 1 of this Article;
b) Administrative fines;
c) Expenses covered by other funding sources;
d) Expenses exceeding the caps prescribed by the Govenrment for: business management expenses allocated by foreign enterprises to permanent establishments in Viet Nam; management lease expenses for prize-winning electronic games and casino operations; loan interest payments of enterprises with related-party transactions; direct welfare expenses for employees; contributions to supplementary pension schemes under the Law on Social Insurance or social security funds, purchase of voluntary pension insurance, and life insurance for employees;
dd) Incorrect or excess provisions established against regulations of the law on provision making;
e) Incorrect or excess fixed asset depreciation charges against regulations of law;
g) Incorrect accrued expenses against regulations of law;
h) Salaries and wages of sole proprietorship owners, owners of single-member limited liability companies owned by an individual; remuneration paid to enterprise founders not directly participating in production and business management; salaries, wages, and other accounting expenses to pay employees but not actually paid or lacking invoices and vouchers as prescribed by law;
i) Loan interest expenses corresponding to the deficit of charter capital; interest expenses during the investment period recorded in investment value; loan expenses to execute oil and gas exploration, extraction, and field development contracts; loan interest expenses for production and business paid to non-credit institutions exceeding the rae prescribed by the Civil Code;
k) Cost recovery expenses exceeding the rate specicified in approved petroleum contracts; where the petroleum contracts do not specify a cost recovery rate, the expenses exceeding the cap set by the Government shall not be deductible;
l) Creditable input value-added tax; value-added tax paid under the credit method; input value-added tax on passenger cars with 9 seats or fewer exceeding the value cap prescribed by the Government; corporate income tax; taxes, fees, charges, and other revenues not calculated as expenses under the law; and late payment interest under tax management law.
Value-added tax paid under the deduction method specified in this Point does not include input value-added tax on goods and services directly related to production and business activities that has not been fully credited but is not eligible for tax refund.
Input value-added tax already accounted for as deductible expense shall not be credited against output value-added tax;
m) Expenses not corresponding to taxable revenue, except for expenses specified in Point b, Clause 1 of this Article; expenses failing to meet spending conditions or contents prescribed by specialized laws;
n) Sponsorships, except for sponsorships specified in Sub-point b5, Point b, Clause 1 of this Article;
o) Capital construction expenditure during the investment phase to form fixed assets; expenses directly related to the increase or decrease of the enterprise's equity;
p) Expenses from business activities in banking, insurance, lottery, securities, BT, BOT, BTO contracts that are incorrect or exceed legal limits;
q) Other non-deductible expenses.
3. The Government shall elaborate on this Article, including additional expense levels, conditions, duration, and scope of application for research and development expenses specified in Point a, Clause 1 of this Article.
The Ministry of Finance shall prescribe dossier requirements for expenses counted as deductible expenses specified in Points b and c, Clause 1 of this Article.
Article 10. Tax rates
1. The standard corporate income tax rate is 20 percent, except for cases specified in Clauses 2, 3, and 4 of this Article and targets enjoying tax rate incentives specified in Article 13 of this Law.
2. A tax rate of 15 percent shall apply to enterprises with total annual revenue not exceeding VND3 billion.
3. A tax rate of 17 percent shall apply to enterprises with total annual revenue exceeding VND3 billion to not more than VND50 billion.
Revenue used as the basis to determine enterprises eligible for the 15 percent and 17 percent tax rates specified in Clauses 2 and 3 of this Article is the total revenue of the immediately preceding corporate income tax period. The determination of total annual renvenue as the application basis shall be implemented under Government regulations.
4. Corporate income tax rates for certain other cases are specified as follows:
a) For oil and gas exploration and extraction activities: The tax rate varies from 25 percent to 50 percent. Based on the location, extraction conditions, and mine reserves, the Prime Minister shall decide the specific tax rate appropriate for each petroleum contract;
b) For exploration and extraction of rare and precious resources (including: platinum, gold, silver, tin, tungsten, antimony, gemstones, rate earths, and other rare/precious resources under the law), the tax rate is 50 percent. Where mines have 70 percent or more of their allocated area located in areas with particularly difficult socio-economic conditions, the tax rate shall be 40 percent.
Article 11. Tax calculation methods
1. The amount of corporate income tax payable in a tax period is calculated by multiplying taxable income by the tax rate, except as provided in Clause 2 of this Article.
2. The Government shall specify corporate income tax payable calculated as a percentage of revenue for the following cases:
a) Enterprises specified in Points c and d, Clause 2, Article 2 of this Law; entities performing tax declaration and payment obligations, timing, and methods for determining revenue for calculating taxable income arising in Viet Nam;
b) Enterprises with total annual revenue not exceeding VND3 billion specified in Clause 2, Article 10 of this Law in cases where renvenue is determinable but expenses and income from production and busness activities are non-determinable;
c) Cooperatives, cooperative unions, public service units, and other organizations specified in Points c, d, and dd, Clause 1, Article 2 of this Law engaged in the production and business of goods and services with taxable corporate income (excluding tax-exempt income specified in Article 4 of this Law) where such units account for revenue but cannot determine expenses and income of production and business activities.
Chapter III
CORPORATE INCOME TAX INCENTIVES
Article 12. Principles and entities eligible for corporate income tax incentives
1. Enterprises shall enjoy corporate income tax incentives according to incentivized sectors and incentivized geographical areas specified in this Article. The levels of corporate income tax incentives shall follow the provisions of Articles 13 and 14 of this Law.
Where other laws provide for corporate income tax incentives different from this Law, the provisions of this Law shall apply, except for the Law on the Capital and Resolutions of the National Assembly providing special/specific mechanisms and policies.
During the same period, if an enterprise is eligible for different tax incentive levels under this Law for the same income item, the enterprise may choose to apply the most favorable tax incentive level.
2. Sectors eligible for corporate income tax incentives include:
a) High-tech application, venture investment in high-tech development on the list of high technologies prioritized for investment and development under the Law on High Technology; strategic technology application as prescribed by law; high-tech incubation, high-tech enterprise incubation; investment in construction and operation of high-tech incubators, high-tech enterprise incubators;
b) Software product manufacturing; network information security product manufacturing and provision of network information security services satisfying conditions under network information security law; key digital technology product manufacturing and service provision, electronic equipment manufacturing under digital technology industry law; research and development, design, manufacturing, packaging, testing of semiconductor chips; construction of artificial intelligence data centers;
c) Production of supporting industry products on the List of supporting industry products prioritized for development prescribed by the Government, meeting one of the following criteria:
c1) Supporting industry products for high technology under the Law on High Technology;
c2) Supporting industry products for production of products in textile-garments, leather-footwear, electronics-informatics (including semiconductor design and manufacturing), automobile manufacturing and assembly, mechanical engineering upto the effective date of this Law that cannot yet produced domestically or can be produced domestically but must meet the technical standards of the European Union or equivalent (if anny) as prescribed by the Minister of Industry and Trade;
d) Production of renewable energy, clean energy, and energy from waste destruction; environmental protection; production of composite materials, light construction materials, and rare or precious materials; national defense and security producton, and industrial mobilization product manufacturing under national defense, security, and industrial mobilization law; production of key chemical industrial products and key mechanical products under the law;
dd) Investment in the development of water plants, power plants, water supply and drainage systems, bridges, roads, railways, airports, seaports, river ports, airfields, stations and other especially important infrastructure works decided by the Prime Minister;
e) High-tech enterprises, high-tech agricultural enterprises under the Law on High Technology; science and technology enterprises under the Law on Science, Technology and Innovation;
g) Investment projects in the field of manufacturing shall meet the following conditions:
g1) Having minimum investment capital of at least VND12,000 billion and disbursing the total registered investment capital within 05 years from the date of investment authorization under investment law;
g2) Using technology satisfying the requirements set out by the Minister of Science and Technology;
h) Investment projects eligible for special investment incentives and support specified in Clause 2, Article 20 of the Law on Investment. The Government shall elaborate on the disbursement timeline for total registered capital of porjects specified in this Point;
i) Forest planting, care, and protection; production, propagation, and breeding of plant and animal varieties; investment in post-harvest preservation of agricultural products, preservation of agricultural, aquatic products and food; production, extraction, and refining of salt, excluding salt production specified in Clause 1, Article 4 of this Law;
k) Cultivation of forest products;
l) Products from cultivated crops, planted forests, livestock breeding, aquaculture, processing of agricultural and aquatic products.
Income from processing agricultural and aquatic products specified in this Point must satisfy the conditions set forth in Clause 1, Article 4 of this Law;
m) High-grade steel production; energy-saving product manufacturing; manufacturing of machinery and equipment for agriculture, forestry, fisheries, and salt production; irrigation equipment manufacturing; animal, poultry, and aquatic feed production;
n) Automobile manufacturing and assembly; production of other digital technology products;
o) Investment and business in technical facilities supporting small and medium-sized enterprises (SMEs), SME incubators; investment and business in co-working spaces supporting innovative SME startups under the Law on Support for Small and Medium-sized Enterprises;
p) People's credit funds, microfinance institutions, cooperative banks;
q) Cooperatives and cooperative unions operating in agriculture, forestry, fisheries, and salt production;
r) Socialization in education and training, vocational training, healthcare, culture, sports, and environment under the List of types, scale criteria, and standards prescribed by the Prime Minister; judicial expertise;
s) Investment in social housing contruction for sale, lease, or lease-purchase to entities entitled to social housing support policies under the Law on Housing;
t) Publishing under the Law on Publishing;
u) Press activities (including print/online press advertising) under the Law on Press.
3. Geographical areas subject to corporate income tax incentives prescribed by the Government shall include:
a) Areas with particularly disadvantaged socio-economic conditions;
b) Areas with disadvantaged socio-economic conditions;
c) Economic zones, high-tech parks, high-tech agricultural zones, and concentrated digital technology zones
4. The Government shall regulate the application of tax incentives for the following cases:
a) Tax incentives based on location criter:
b) Tax incentives in agriculture, forestry, fisheries, and salt production;
c) In case where income is generated in the first tax period or income is generated from investment projects (including new investment projects, expansion projects, high-tech enterprises, high-tech application enterprises, science and technology enterprises) where the time generating revenue or income eligible for tax incentives is less than 12 months.
5. Enterprises established or having investment projects resulting from mergers, consolidations, divisions, separations, ownership transformations, or corporate form conversions shall be responsible for paying corporate income tax liabilities (including fines, if any), and shall inherit corporate income tax incentives (including un-transferred loss balances) of the enterprise or investment project prior to such restructuring, provided that they continue to meet requirements for corporate income tax incentives and loss carryforward conditions under the law.
Article 13. Preferential tax rates
1. A preferential tax rate of 10 percent for 15 years shall apply to:
a) Income of enterprises from implementing new investment projects specified in Points a, b, c, d, and dd, Clause 2, Article 12 of this Law; income of enterprises specified in Point e, Clause 2, Article 12 of this Law;
b) Income of enterprises from implementing investment projects specified in Points g and h, Clause 2, Article 12 of this Law;
c) Income of enterprises from implementing new investment projects in areas specified in Point a, Clause 3, Article 12 of this Law:
d) Income of enterprises from implementing new investment projects in high-tech zones, high-tech agricultural zones, concentrated digital technology zones; new investment projects in economic zones located in incentivized geographical areas specified in Points a and b, Clause 3, Article 12 of this Law. Where an investment project in an economic zone spans both incentivized and non-incentivized geographical areas, tax incentives shall be determined under Government regulations.
2. A preferential tax rate of 10 percent shall apply to:
a) Income of enterprises from activities in sectors/business lines specified in Points k and I, Clause 2, Article 12 of this Law in incentivized geographical areas specified in Point b, Clause 3, Article 12 of this law;
b) Income of enterprises from activities in sectors/business lines specified in Points i, r, and s, Clause 2, Article 12 of this Law;
c) Income of publishers from activities in sectors/business lines specified in Point t, Clause 2, Article 12 of this Law;
d) Income of cooperatives and cooperative unions specified in Point q, Clause 2, Article 12 of this Law not located in geographical areas specified in Clause 3, Article 12 of this law.
dd) Income of press agencies in sectors/business lines specified in Point u, Clause 2, Article 12 of this Law;
3. A preferential tax rate of 15 percent shall apply to income of enterprises from activities in sectors/business lines specified in Point l, Clause 2, Article 12 of this Law not located in geographical areas specified in Clause 3, Article 12 of this Law.
4. A preferential tax rate of 17 percent for 10 years shall apply to:
a) New investment projects in incentivized sectors/ business lines specified in Points m, n, and o, Clause 2, Article 12 of this Law;
b) New investment projects implemented in geographical areas specified in Point b, Clause 3, Article 12 of this Law;
c) New investment projects in economic zones not located in geographical areas specified in Points a and b, Clause 3, Article 12 of this Law.
5. A preferential tax rate of 17 percent shall apply to income of enterprises specified in Point p, Clause 2, Article 12 of this Law.
6. Extension of preferential tax rate periods and reduced tax rate application are as follows:
a) The Prime Minister may decide to extend the period of preferential tax rate application for an additional duration not exceeding 15 years for the following projects:
a1) New investment projects specified in Points a, b, d, and dd, Clause 2, Article 12 of this Law, with a minimum investment capital of VND6,000 billion, having significant socio-economic impacts requiring special encouragement;
a2) Investment projects specified in Point g, Clause 2, Article 12 of this Law meeting one of the following criteria:
- Producing goods with global competitiveness, achieving annual revenue of over VND20,000 billion at the latest within 5 years from generating project revenue;
- Regularly employing over 6,000 workers determined under labor law;
- Investment projects in technical infrastructure sectors, including: water plants, power plants, water supply/drainage systems, bridges, roads, railways, airports, seaports, river ports, airfields, stations, new energy, clean enery, energy-saving industries, and petrochemical projects;
b) For new investment projects specified in Point h, Clause 2, Article 12 of this Law, the Prime Minister may decide to apply a reduced tax rate of not more than 50 percent of the tax rate specified in Clause 1 of this Article; the duration of preferential tax rate application shall not exceed 1.5 times the standard duration in Clause 1 of this Article, and may be extended by up to 15 years, not exceeding the term of the investment project.
7. The period of preferential tax rate application for income from implementing new investment projects under this Article (including projects specified in Point g, Clause 2, Article 12 of this Law) shall be calculated from the first year the new investment project generates revenue.
Where an enterprise is granted a high-tech enterprise certificate, high-tech agricultural enterprise certificate, science and technology enteprise certificate, high-tech application project certificate, or certificate of incentives for projects manufacturing supporting industry products after generating revenue, the preferential tax rate period shall be calculated from the year of certificate issuance.
Article 14. Tax exemption and reduction
1. Tax exemption for a maximum of 4 years and a 50 percent reduction of payable tax for a maximum of the subsequent 9 years shall apply to:
a) Income of enterprises specified in Clause 1, Article 13 of this Law;
b) Income of enterprises specified in Point r, Clause 2, Article 12 of this Law located in geographical areas specified in Points a and b, Clause 3, Article 12 of this Law; if not located in geographical areas specified in Points a and b, Clause 3, Article 12 of this Law, tax exemption shall apply for a maximum of 4 years and a 50 percent tax reduction for a maximum of the subsequent 5 years.
2. Tax exemption for a maximum of 02 years and a 50 percent reduction of payable tax for a maximum of the subsequent 04 years shall apply to income of enterprises specified in Clause 4, Article 13 of this Law.
3. For new investment projets specified in Point h, Clause 2, Article 12 of this Law, the Prime Minister may decide to extend the tax exemption and reduction period by up to 1.5 times the duration specified in Clause 1 of this Article.
4. The tax exemption and reduction period shall be calculated from the first year an investment project generates taxable income; if the project does not generate taxable income in the first 03 years from its first revenue-generating year, the tax exemption and reduction period shall be calculated from the 4th year.
Where an enterprise is granted relevant certificates of incentives after generating income, the tax exemption and reduciton period shall be calculated from the year of certificate issuance.
If there is no taxable income in the year of certificate issuance, the tax exemption and reduction period shall be calculated from the first income-generating year; if no taxable income arises within 03 years from the year of certificate issuance, it shall be calculated from the 4th year following the year of certifiate issuance.
5. Tax incentives for expansion investment projects:
a) Active enterprises implementing expansion investment projects (scale expansion, capacity enhancement, technology renewal, pollution reduction/environmental improvement) in incentivized sectors or geographical areas under Article 12 of this Law shall enjoy tax incentives on the incremental income from expansion investment based on the remaining incentive period of the active project, without needing to separately account for incremental income from expansion investment versus active project income;
b) Where the active project has expired its tax incentive period, incremental income from the expansion investment project satisfying criteria in Clause 6 of this Article shall be entitled to tax exemption and reduction, but not preferential tax rates. The exemption/reduction duration equals that of a new project in the same incentivized sector/business line, and geographical area, calculated from the year the expansion project completes its registered capital deployment.
Enterprises must separately account for incremental income from expansion investment. If separate accounting is impossible, expansion income shall be allocated based on the ratio of newly invested fixed asset historical cost brought into operation over the total fixed asset historical cost;
c) Tax incentives under this Clause do not apply to expansion investments resulting from mergers, acquisition of active enterprise, or active investment projects.
6. Expansion investment projects eligible for incentives under Point b, Clause 5 of this Article must meet one of the following criteria:
a) Additional fixed asset historical cost upon completing the disbursement of registered capital reaches the minimum threshold set by the Government corresponding to incentivized sectors/business lines or geographical areas;
b) Ratio of additional fixed asset historical cost upon completing the disbursement of registered capital increases by at least 20 perent compared to total fixed asset historial cost prior to expansion;
c) Additional designed capacity upon completing the disbursement of registered capital increases by at least 20 perent compared to designed capacity prior to expansion.
Article15. Other tax exemption and reduction cases
1. Manufacturing, construction, and transportation enterprises employing a large number of female employees shall be granted a corporate income tax reduction equal to the additional expenses incurred for female employees.
2. Enterprises employing a large number of ethnic minority employees shall be granted a corporate income tax reduction equal to the additional expenses incurred for ethnic minority employees.
3. Enterprises transferring technology in prioritized fields to organzations and individuals in areas with disadvantaged socio-economic conditions, or public service units providing public services in areas with disadvantaged socio-economic conditions, shall be entitled to a 50 percent reduction in corporate income tax on income derived from such technology transfer or service provision.
4. Enterprises specified in Clauses 2 and 3, Article 10 of this Law newly established from household businesses shall be exempt from corporate income tax for 02 consecutive years from the year of generating taxable income.
5. Public science and technology organizations and non-profit public higher education institutions shall be exempt from tax under Government regulations.
6. The Government shall elaborate on this Article.
Article 16. Loss carryforward
1. Enterprises incurring losses may carry forward losses to the following year; such losses shall be deducted from taxable income. The loss carryforward period shall not exceed five consecutive years following the loss-incurring year.
2. Enterprises with losses from the transfer of mineral exploration/ extraction projects; transfer of rights to participate in mineral exploration, extraction, and processing projects; or transfer of rights to mineral exploration, extraction and processing may carry forward such losses to the following year against taxable income from those specific activities. The carryforward period shall comply with Clause 1 of this Article.
3. The Government shall elaborate on this Article.
Article 17. Establishment of Science and Technology Development Fund
1. Enterprises, organizations, and public service units established under Vietnamese law may appropriate a maximum of 20 percent of annual taxable income to establish a Science and Technology Development Fund.
2. Within 05 years from appropriation under Clause 1 of this Article, if the Fund is unused or used less than 70 percent, or used for improper purposes, the entity must remit to the state budet the corporate income tax amount calculated on the unused or improperly used portion, plus interest arising on that corporate income tax amount.
The corporate income tax rate used to calculate clawback tax is the rate applicable to enterprises, organizations, and public service units during the appropriation period.
The interest rate applied to tax clawed back on unused funds is the five-year or 10-year Treasury bond interest rate issued closest to the clawback date, with an interest calculation period of 02 years.
The interest rate applied to tax clawed back on improperly used funds shall be late payment interest rate under the Law on Tax Administration, calculated from from fund appropriation until recovery.
3. Enterprises, organizations, and public service units shall not account for expenditures from the Science and Technology Development Fund as deductible expenses when determining taxable income.
4. The Science and Technology Development Fund shall be utilized in accordance with science, technology, and innovation legislation.
5. Operating enterprises undergoing structural changes (mergers, consolidations, separations, divisions, ownership transformations, or corporate form conversions) shall inherit and assume legal responsibility for managing and utilizing the Science and Technology Development Fund.
Article 18. Conditions for applying tax incentives
1. Corporate income tax incentives under Articles 13, 14, and 15 of this Law shall apply to enterprises implementing accounting regimes, invoices, vouchers, and paying tax under declaration method.
Corporate income tax incentives for new investment projects under Articles 13 and 14 of this Law shall not apply to mergers, consolidations, divisions, separations, ownership transformations, corporate form conversions, or other cases prescribed by the Government.
2. Enterprises must separately account for income from production and business activities entitled to tax incentives under Articles 4, 13, 14, and 15 of this Law from non-incentivized income; where separate accounting is impossible, incentivized income shall be determined according to the ratio of incentivized revenue or expenses over total enterprise revenue or total expenses.
3. The tax rates of 15 percent and 17 under Clauses 2 and 3, Article 10 of this Law and tax incentives under Articles 4, 13, 14, and 15 of this Law shall not apply to:
a) Income from capital transfer, transfer of capital contribution rights; income from real estate transfer, except social housing construction under Point s, Clause 2, Article 12 of this Law; income from investment project transfer, except mineral processing projects, from transfer of rights to participate in investment projects, from transfer of mineral exploration, extraction, and processing rights; income from overseas production and business activities;
b) Income from oil, gas, and rare/precious resource exploration and extraction, and mineral exploration and extraction activities;
c) Income from online video game production and business; income from goods and service production and business subject to special consumption tax under the Law on Special Consumption Tax, excluding projects manufacturing, assembling automobiles, airplanes, helicopters, gliders, yachts, and oil refining;
d) Specicial cases prescribed by the Government.
4. The tax rates of 15 percent and 17 percent specified in Clauses 2 and 3, Article 10 of this Law shall not apply to enterprises that are subsidiaries or related parties where the affiliated enterprise does not meet conditions for applying tax rates under Clauses 2 and 3, Article 10 of this Law.
5. In case where an enterprise fails to satisfy tax incentive conditions, competent authorities shall perform tax clawbacks and impose penalties for violations in accordance with the law.
6. The Government shall elaborate on Clause 5 of this Article. The Ministry of Finance shall specify procedures and dossier requirements for enjoying tax incentives under Article 4, 13, 14 and 15 of this Law
Chapter IV
PROVISIONS OF IMPLEMENTATION
Article 19. Effect
1. This Law shall take effect from October 1, 2025, and apply from the 2025 corporate income tax period.
2. Law on Corporate Income Tax No. 14/2008/QH12, as amended and supplemented by 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/QH1, shall cease to be effective from the effective date of this Law.
3. In case the Organization for Economic Cooperation and Development (OECD) and the United Nations provide more favorable regulations or guidelines on taxing rights for source countries, including Viet Nam, the Government shall be assigned to detail the implementation.
Article 20. Transitional provisions
1. Enterprises with investment projects entitled to corporate income tax incentives under corporate income tax laws at the time of license issuance, investment certificate issuance, or investment authorization under investment law shall, upon amendments/supplements to corporate income tax laws, have the right to choose tax rate incentives and tax exemption/reduction duration under the law at the licensing/authorization date or under the newly amended/supplemented law for the remaining period, provided they meet conditions under the new law.
2. Where an enterprise has an investment project that was not eligible for incentives under legal documents on corporate income tax issued before the effective date of this Law but become eligible under this Law, it shall be entitled to apply incentives under this Law for the remaining period starting from the 2025 tax period
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This Law was passed by the 15th National Assembly of the Socialist Republic of Viet Nam at its 9th session on June 14, 2025./.
For reference only