Q&A: Three-year CIT exemption period for SMEs first registered before Resolution 198/2025/QH15 took effect
RegHub explainer by New MarketerLast updated:
Based on:Nghị định số 20/2026/NĐ-CP ngày 15/01/2026; Nghị quyết số 198/2025/QH15 - Ministry of Finance
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Dong Nai Tax Department No. 10 clarifies: under Article 1(2), Article 7(3) and Article 9 of Decree 20/2026/ND-CP, the three-year CIT exemption for newly registered SMEs applies from the date Resolution 198/2025/QH15 took effect. A company registered in June 2022 - before the Resolution's effective date - is entitled only to the remaining portion of the three-year period counted from its initial registration date. Since the three-year window from June 2022 expired before June 2025 - prior to the Resolution's effective date - no remaining exemption time existed when the Resolution came into force. The company is therefore not entitled to CIT exemption for January through May 2025.
Background
A company first registered in June 2022 asks: based on Article 7(3) of Decree 20/2026/ND-CP, does its three-year CIT exemption run from June 2022 to May 2025? And is it exempt from CIT for January through May 2025?
Response from Dong Nai Tax Department No. 10
Under Article 1(2), Article 7(3), and Article 9 of Decree 20/2026/ND-CP:
- The provision applies from the effective date of Resolution 198/2025/QH15.
- SMEs registered before Resolution 198/2025/QH15 took effect that still have remaining exemption time may enjoy the exemption for the remaining period.
Conclusion: The company registered in June 2022; its three-year exemption window expired in May 2025 — before Resolution 198/2025/QH15 took effect. Therefore, no remaining exemption time existed when the Resolution became effective, and the company is not entitled to CIT exemption for January through May 2025 under this provision.
Applicable Regulations
- Decree 20/2026/ND-CP dated 15 January 2026.
- Resolution 198/2025/QH15.