Non-Cash Payment Requirement for Wages of VND 5 Million or More as Deductible Expense Under Decree 320/2025/ND-CP
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The Ministry of Finance confirms that salary and wage payments of **VND 5 million or more per transaction** must be accompanied by **non-cash payment documentation** to qualify as a deductible expense for corporate income tax (CIT) purposes, effective from 15 December 2025 (the effective date of Decree 320/2025/ND-CP). What constitutes "non-cash payment documentation" is determined under Article 26 of Decree 181/2025/ND-CP dated 01/7/2025, implementing the VAT Law. This requirement applies under Article 9, clause C of Decree 320/2025/ND-CP and makes no distinction between wages and other goods/services payments. The authoritative reference is Official Letter 218/CST-TN dated 27/01/2026 from the Department of Tax, Fee and Charge Policy Management, Ministry of Finance.
Question
Decree 320/2025/ND-CP states that expenses with non-cash payment documentation for single transactions of VND 5 million or more are deductible (Article 9, clause C). However, Article 10, clause 8 lists non-deductible employee expenses without mentioning a non-cash payment requirement. Do salary, allowances, and per-diem payments of VND 5 million or more per transaction need bank transfer documentation?
Official Guidance (Official Letter 218/CST-TN dated 27/01/2026)
Conclusion: Yes - salary and wage payments of VND 5 million or more per transaction must have non-cash payment documentation to be deductible for CIT purposes.
Conditions for Wage Deductibility
- Must meet conditions in Article 9, clause 1 of Decree 320/2025/ND-CP (actual cost, valid documentation)
- Must not fall under non-deductible items in Article 10, clause 8 (e.g., wages without contracts, non-compliant payments)
- Single transactions of VND 5 million or more must have non-cash payment documentation per Article 9, clause C
Effective Date
From 15 December 2025 - the effective date of Decree 320/2025/ND-CP.
Determining Non-Cash Payment Documentation
Governed by Article 26 of Decree 181/2025/ND-CP dated 01/7/2025 implementing the VAT Law.
Filing Practice
Enterprises self-declare and settle tax returns. For specific questions, contact the managing tax authority directly.
Legal basis:
- Decree 320/2025/ND-CP dated 15/12/2025 (Article 9 clause C, Article 10 clause 8)
- Decree 181/2025/ND-CP dated 01/7/2025 (Article 26)
- Official Letter 218/CST-TN dated 27/01/2026