Official Letter
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Corporate Income Tax

CIT Incentives for Science and Technology Enterprises: Applying Remaining Incentives from 2025

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Based on:Nghị định số 13/2019/NĐ-CP ngày 01/02/2019; Luật Thuế TNDN số 67/2025/QH15; Nghị định số 268/2025/NĐ-CP ngày 14/10/2025 - 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 provided guidance on CIT incentives for a science and technology (S&T) enterprise that received its certification in 2017 but has not yet applied the incentives, and now seeks to claim the remaining benefits from 2025. Under CIT Law No. 67/2025/QH15, certified S&T enterprises may apply a 10% tax rate for 15 years, with a 4-year tax exemption and a 50% reduction for the following 9 years. Article 68 of Decree 268/2025/NĐ-CP confirms that enterprises already holding S&T enterprise certificates that have not yet claimed incentives may continue to do so for the remaining eligible period. Note that certification conditions have changed under Decree 268/2025/NĐ-CP (authority to issue now rests with provincial People's Committees; additional R&D spending and S&T workforce conditions now apply). Enterprises must review their actual documentation and contact the direct tax authority to determine the remaining incentive period and applicable conditions.

Question

An S&T enterprise received its certificate in 2017 but has not applied the tax incentives. In 2025 it wishes to apply the remaining CIT incentives: 10% tax rate, 4-year exemption, 50% reduction for the following 9 years. Are the conditions met in 2025?

Applicable Regulations

Article 12, Clause 1 of Decree 13/2019/NĐ-CP: Income of S&T enterprises from production/business of products derived from S&T results is entitled to: 4-year tax exemption and 50% tax reduction for the following 9 years.

CIT Law No. 67/2025/QH15 (Article 12, Clause 2e; Article 13, Clause 1; Article 14, Clause 1): S&T enterprises in preferential sectors may apply a 10% rate for 15 years, with 4-year exemption and 50% reduction for the following 9 years. Timing per Article 13, Clause 7 and Article 14, Clause 4 of CIT Law No. 67/2025/QH15.

Article 53 of Decree 268/2025/NĐ-CP: S&T enterprise certificates are reviewed every 3 years. Revocation upon: dissolution/bankruptcy, failure to report for 3 consecutive years, loss of ownership/legal use of technology, failure to meet conditions for 3 consecutive years.

Article 68 of Decree 268/2025/NĐ-CP: Enterprises holding S&T enterprise certificates that have not yet claimed incentives may continue to claim them for the remaining eligible period under prior legislation. If the new conditions under Decree 268/2025/NĐ-CP are met, the enterprise may apply for a new certificate and claim incentives under the new rules.

Conclusion

The S&T enterprise with a 2017 certificate that has not yet claimed incentives: may claim the incentives for the remaining eligible period. The enterprise must identify the first year of taxable income to calculate the remaining exemption/reduction period, and should contact the direct tax authority for confirmation.

Nghị định số 13/2019/NĐ-CP ngày 01/02/2019; Luật Thuế TNDN số 67/2025/QH15; Nghị định số 268/2025/NĐ-CP ngày 14/10/2025