17% CIT Rate for 100% Foreign-Owned Subsidiary with Revenue Between VND 3 and 50 Billion
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Based on:Nghị định số 320/2025/NĐ-CP ngày 15/12/2025 - Ministry of Finance
This explanation was generated by AI and checked by an automated AI review, not by a human expert. It is not legal, tax or accounting advice and may contain errors. Check the official document before you rely on it.
The Ministry of Finance clarifies whether Willer Vietnam Co., Ltd. - a wholly-owned subsidiary of Willer Inc. (Japan) with FY2025 revenue of VND 10.2 billion - qualifies for the 17% CIT rate under Decree No. 320/2025/ND-CP. Under Article 11(4)(c) of Decree No. 320/2025/ND-CP, the 15% and 17% preferential rates do not apply to Vietnamese-registered companies that are subsidiaries of, or affiliated with, entities that do not themselves qualify for those preferential rates. Since Willer Inc. (Japan) is a foreign enterprise not subject to Vietnamese CIT, the Ministry advises the business to self-assess the applicable rules and contact the directly managing tax authority for case-specific guidance.
17% CIT Rate for Foreign-Owned Subsidiaries
Responding authority: Ministry of Finance (Hanoi Tax Department) Inquirer: Le Thi Thu Ha - Willer Vietnam Co., Ltd. (TIN: 0107535833) Date: 2 April 2026
Background
- Willer Vietnam LLC: 100% owned by Willer Inc. (Japan)
- FY2025 total revenue: VND 10,242,591,648 (approximately VND 10.2 billion)
- Revenue condition satisfied for 17% rate (VND 3-50 billion range)
- Issue: Must the Japanese parent's conditions be considered?
Applicable Rules
Article 11(4) of Decree No. 320/2025/ND-CP:
- 15% rate: Enterprises with annual revenue ≤ VND 3 billion
- 17% rate: Enterprises with annual revenue from above VND 3 billion to ≤ VND 50 billion
- Revenue base: Total sales and service revenue + financial income + other income per the production/business results annex to the CIT finalization declaration for the immediately preceding tax year
Article 11(4)(c) of Decree No. 320/2025/ND-CP - EXCLUSION CLAUSE: 'The 15% and 17% rates do not apply to Vietnamese-registered enterprises that are subsidiaries of, or affiliated with, entities that do not themselves satisfy the conditions for the preferential rates under paragraphs 2 and 3 of this Article.'
Tax Authority Guidance
The business must self-assess and contact the directly managing tax authority for case-specific guidance based on actual documents and circumstances.
Practical implication: Since Willer Inc. (Japan) is not a Vietnamese CIT taxpayer and cannot qualify for the 15% or 17% rates in Vietnam, Willer Vietnam is likely ineligible for the 17% preferential rate and must apply the standard 20% CIT rate.