Consolidated Document No. 113/VBHN-VPQH: Corporate Income Tax Law (consolidated through April 2026)
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Based on:113/VBHN-VPQH (hợp nhất Luật số 67/2025/QH15) - Government Official Gazette
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This is the official consolidated version of Vietnam's Corporate Income Tax (CIT) Law (Law No. 67/2025/QH15, effective from 1 October 2025 and applied from the 2025 tax period), published by the National Assembly Office on 20 May 2026. It integrates every amendment made to date, through Law No. 09/2026/QH16, which took effect on 24 April 2026. This is the core legal text every business operating in Vietnam must follow when calculating and declaring CIT. On tax rates, the standard rate remains 20 percent, but businesses with annual revenue of up to VND 3 billion pay only 15 percent, and those with revenue from over VND 3 billion up to VND 50 billion pay 17 percent - a notable relief measure for small and micro enterprises. The law also adds a full CIT exemption for businesses whose annual revenue falls below a threshold still to be set by the Government (Article 4.14a, effective 1 January 2026); the specific figure will be issued later in an implementing decree. The law also confirms that foreign enterprises running e-commerce or digital-platform businesses in Vietnam are taxable even without a permanent establishment there. On incentives, preferential rates of 10 percent (for 10, 15, or 25 years depending on the sector), plus tax holidays of 2-4 years and 50 percent reductions for a further 4-9 years, continue to apply to high-tech, strategic technology, R and D, software production, renewable energy, and agriculture in disadvantaged areas, among other fields. The new High-Tech Law (effective 1 July 2026) significantly expands incentive eligibility for strategic-technology and high-tech enterprises, including a new 10 percent rate for 25 years - the longest incentive period offered to date. SME owners and accountants should re-check how their revenue is classified to confirm which of the 15/17/20 percent rates applies to them, and should watch for the implementing decrees still to come, especially the one that will set the micro-enterprise exemption threshold.
About this document
Consolidated Document No. 113/VBHN-VPQH, certified by the National Assembly Office on 20 May 2026 (signed by Chairman Le Quang Manh) and published in Official Gazette No. 303 dated 2 June 2026, merges the full text of Corporate Income Tax Law No. 67/2025/QH15 (passed 14 June 2025, effective 1 October 2025) with amendments introduced by six subsequent laws: the Cybersecurity Law No. 116/2025/QH15, the Criminal Judgment Enforcement Law No. 127/2025/QH15, the High-Tech Law No. 133/2025/QH15 (most provisions effective 1 July 2026), Law No. 141/2025/QH15 amending the Public Debt Management Law (effective 1 January 2026), the Investment Law No. 143/2025/QH15 (effective 1 March 2026), and Law No. 09/2026/QH16, which simultaneously amends the PIT, VAT, CIT, and Special Consumption Tax laws (effective 24 April 2026, with some articles applying from 1 January 2026). This is the primary legal text, not commentary - everything below is a structured summary organized by the law's chapters and articles.
Chapter I - General Provisions
Taxpayers (Article 2): enterprises established under Vietnamese law; foreign enterprises with or without a permanent establishment in Vietnam - including e-commerce and digital-platform businesses; cooperatives and cooperative unions; public service units; and other organizations earning business income. A permanent establishment now explicitly includes an «e-commerce platform or digital platform» through which a foreign enterprise supplies goods or services in Vietnam.
Taxable income (Article 3): income from production and business plus other income (capital transfers, real estate, investment projects, mineral exploitation rights, deposit/loan interest, sponsorship received, overseas business income, and more). Vietnamese enterprises investing abroad may credit tax already paid in the host country, capped at the CIT amount computed under Vietnamese law.
Tax-exempt income (Article 4): 15 categories, including agriculture/forestry/fishery in disadvantaged areas, agricultural technical services, scientific research/innovation/digital transformation contracts (exempt up to 3 years), businesses employing 30 percent or more disabled/rehabilitated/HIV-affected staff, sponsorship for education-health-charity, revaluation gains on equitization, first-issuance carbon credits and green bonds, and income of the Vietnam Development Bank and Social Policy Bank. A significant new addition: clause 14a (added by Law 09/2026/QH16, effective 1 January 2026) fully exempts businesses whose total annual revenue is at or below a level the Government will set from time to time - the exact threshold is still pending an implementing decree.
Tax period (Article 5): the calendar year or a fiscal year chosen by the business (must notify the tax authority before applying).
Chapter II - Tax Basis and Calculation Method
Formula (Articles 6-8): Taxable income = Assessable income - Exempt income + Carried-forward losses. Assessable income = Revenue - Deductible expenses + Other income. Revenue is the entire proceeds from sales, processing, or services (including subsidies and surcharges), regardless of whether payment has been received.
Deductible / non-deductible expenses (Article 9): expenses are deductible if actually incurred for business operations and supported by invoices and non-cash payment documents. A long list is non-deductible: administrative fines, amounts exceeding government-set caps (related-party loan interest, direct employee welfare, etc.), incorrect or excess depreciation, salaries paid to sole proprietors or single-member LLC owners, already-credited input VAT, CIT itself, and late-payment interest.
Tax rates (Article 10): standard rate 20 percent; 15 percent for businesses with annual revenue up to VND 3 billion; 17 percent for revenue over VND 3 billion up to VND 50 billion (based on the prior tax period's revenue); oil and gas exploration 25-50 percent as decided by the Prime Minister per contract; extraction of precious minerals (platinum, gold, silver, rare earths, etc.) 50 percent, reduced to 40 percent if 70 percent or more of the mine area lies in a specially disadvantaged region.
Chapter III - CIT Incentives
Preferred sectors and locations (Article 12): a long list including high-tech/strategic technology, software, semiconductor chips, supporting industries, renewable energy, infrastructure (power, water, bridges, roads, ports, airports), projects with capital of VND 12,000 billion or more, agriculture/forestry/fishery, social housing, publishing, press, and socialized education/health services. Preferred locations include specially disadvantaged and disadvantaged areas plus economic zones, hi-tech zones, and concentrated digital-technology zones.
Preferential rates (Article 13): 10 percent for 15 years for new investment projects in priority sectors or specially disadvantaged areas; new: 10 percent for 25 years for strategic-technology R and D centers and Group-1 high-tech enterprises (under the new High-Tech Law, effective 1 July 2026) - the longest incentive period offered to date; an indefinite 10 percent rate for certain sectors in disadvantaged areas; 15 and 17 percent for 10 years in other cases. The Prime Minister may extend the incentive period by up to 15 more years for projects with capital of VND 6,000 billion or more that have major socio-economic impact.
Tax holidays and reductions (Articles 14-15): up to 4 years' exemption plus a 50 percent reduction for a further 9 years (for projects on the 10 percent rate); 2 years' exemption plus a 50 percent reduction for 4 years (for projects on the 17 percent rate). Expansion projects meeting set criteria (fixed-asset growth, capacity, or capital-share increases of 20 percent or more) get separate incentives on the incremental income. Businesses newly established from household businesses (on the 15/17 percent rate) get a 2-year continuous exemption.
Loss carryforward and S&T Development Fund (Articles 16-17): losses may be carried forward for up to 5 consecutive years. Businesses may set aside up to 20 percent of taxable income for a Science and Technology Development Fund; if 70 percent of it goes unused or is misused after 5 years, the tax plus interest is clawed back.
Conditions for incentives (Article 18): available only to businesses keeping proper accounting records, invoices, and declarations; incentive income must be tracked separately; incentives do not apply to income from capital/real estate/project transfers, oil and gas activity, online gaming, or goods subject to Special Consumption Tax (except certain specified projects).
Chapter IV - Implementation
Law No. 67/2025/QH15 took effect on 1 October 2025 and applies from the 2025 tax period, replacing CIT Law No. 14/2008/QH12 (as previously amended several times). Businesses already receiving incentives under prior rules may choose to keep those terms or switch to the new ones if they qualify, for the remaining incentive period starting from the 2025 tax period.