CIT deductible expense guidance for cash interest payments by People's Credit Funds under the VND 5 million non-cash payment threshold rule
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Based on:Luật Thuế TNDN số 67/2025/QH14 Điều 9; Nghị định 320/2025/NĐ-CP Điều 9 - Ministry of Finance
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The Ministry of Finance confirmed that the non-cash payment requirement for expenses of VND 5 million or more per transaction — under Point c, Clause 1, Article 9 of Decree 320/2025/ND-CP — applies to all enterprise expenditures including interest payments by People's Credit Funds. Non-cash payment documentation follows VAT law requirements. The rule applies from 15 December 2025 when Decree 320/2025/ND-CP took effect. For the specific situation of People's Credit Funds (specialized operations, depositors mainly elderly and rural residents without bank accounts), the tax authority advised contacting the directly managing tax office for case-specific guidance based on actual records and circumstances.
Background
A People's Credit Fund pays savings deposit interest in cash at depositors' request — depositors are mainly elderly rural residents without bank accounts. Questions: Does this fall under the non-cash payment requirement? Is it deductible for CIT purposes?
Applicable Regulations
Point c, Clause 1, Article 9 of CIT Law No. 67/2025/QH14 (effective 01/10/2025, applies from the 2025 tax year): Enterprises may deduct expenses if supported by invoices and non-cash payment documents as required by law.
Clause 1, Article 9 of Decree 320/2025/ND-CP (effective 15/12/2025): Non-cash payment documentation is required for individual transactions of VND 5 million or more (per VAT law requirements).
Ministry of Finance Guidance
The non-cash payment requirement applies generally to all enterprise expenditures. The specific situation of People's Credit Funds should be clarified with the directly managing tax authority based on the entity's actual documentation and circumstances.