Knowledge base

The Ministry of Finance clarifies the conditions for a 3-year corporate income tax (CIT) exemption for small and medium enterprises (SMEs) registering for the first time under Decree 20/2026/ND-CP, implementing National Assembly Resolution 198/2025/QH15 on private sector development. The exemption period runs continuously from the first year of initial business registration. However, the benefit does not apply to enterprises formed through mergers, splits, or where the legal representative or largest shareholder previously held the same role at another enterprise that is still operating or was dissolved less than 12 months before the new enterprise was established. Enterprises self-determine their eligibility and file tax returns accordingly. If the tax-exempt operating period in the first tax year is less than 12 months, the enterprise may choose to apply the exemption that year or register to begin from the following tax year.

Consolidated Document No. 10/VBHN-BXD merges base Decree No. 92/2016/ND-CP with five rounds of amendments (most recently Decree No. 14/2026/ND-CP, effective January 15, 2026) into a single text setting business conditions for six aviation business lines: air transport, airports, airport aviation services, aircraft design/manufacturing/maintenance, air navigation services, and aviation personnel training. Key requirements include very high minimum capital thresholds (VND 30-700 billion depending on the business type), foreign ownership caps (34% for airlines, 30% for airports), minimum fleet sizes, and a multi-tier licensing process running through the Civil Aviation Authority of Vietnam, the Ministry of Construction, and the Prime Minister. The text also details age limits for imported aircraft, grounds for license revocation, and reporting obligations for licensed businesses. This is a sector-specific decree aimed at large aviation investors and operators (airlines, airport operators, ground-service providers) rather than general SMEs, and it contains no tax, accounting, e-invoice, or general labor content. The most notable change in this consolidation is Decree No. 14/2026/ND-CP, which trims certain paperwork requirements and allows results to be delivered electronically.

A small and medium enterprise in Ho Chi Minh City asked when the implementing decree for National Assembly Resolution 198/2025/QH15 dated 17/05/2025 (on special mechanisms and policies for private sector development) would be officially issued, as the draft had closed for public comment in September 2025 but no decree had been published by January 2026. The Ministry of Finance confirmed: On 15/01/2026, the Government issued Decree 20/2026/ND-CP providing detailed guidance on implementing certain articles of Resolution 198/2025/QH15. The Ministry instructed the company to study the Decree to properly apply its provisions for the 2025 tax year and subsequent years. This is key information for SMEs newly established in 2025 that have been waiting to apply tax incentives under Resolution 198/2025/QH15.

Consolidated Document 12/2026/VBHN-QD-BKHCN, issued by the Ministry of Science and Technology, merges Decision 30/2018/QD-TTg with the amendments made by Decision 02/2026/QD-TTg (effective January 8, 2026). It sets out the procedure for confirming goods used directly for technology incubation, science-and-technology enterprise incubation, and technology innovation activities, as well as specialized transport vehicles within a technology line used directly for an investment project's production. This confirmation is the basis for such goods and vehicles to qualify for import duty exemption under the Law on Export and Import Duties and Decree 134/2016/ND-CP. The 2026 amendments simplify the paperwork: they allow the receiving authority to pull existing electronic data (investment registration certificate, enterprise registration certificate) instead of requiring paper copies from the applicant, and allow online filing through the National Public Service Portal. Processing timelines are largely unchanged: 3 working days to check the file's validity, 7 working days (technology incubation/innovation) or 10 days (specialized transport vehicles) to respond, extendable up to 14-15 working days (technology incubation/innovation) or 20 days (specialized transport vehicles) if a review committee is convened. Businesses with investment projects involving technology incubation, technology innovation, or the import of specialized transport vehicles for a production line should reference this consolidated text when preparing an application for import duty exemption confirmation, rather than checking Decision 30/2018 and Decision 02/2026 separately.

Consolidated Document No. 14/2026/VBHN-QD-BKHCN merges Decision No. 18/2019/QD-TTg (effective 15 June 2019) with amendments under Decision No. 02/2026/QD-TTg (effective 8 January 2026) into one unified text governing the import of used machinery, equipment and technology lines under HS Chapters 84 and 85 for manufacturing use in Vietnam. Substantively, businesses importing used equipment must keep equipment age at 10 years or less (certain sectors such as mechanical engineering, wood processing and paper have a separate appendix allowing up to 15-20 years), and the equipment must meet relevant national technical regulations or standards, or the national standards of a G7 country or South Korea, on safety, energy efficiency and environmental protection. For used technology lines, additional criteria apply: remaining capacity or efficiency of at least 85% of the original design, material and energy consumption not exceeding 115% of design levels, and the technology must currently be in use at no fewer than three production facilities in OECD countries. Customs dossiers must include an inspection certificate issued by an inspection body designated by the Ministry of Science and Technology; customs clears the shipment only when the certificate confirms the equipment meets the criteria. Where equipment exceeds the age limit but retains 85% or more of its design capacity or efficiency, a business may apply to the Ministry of Science and Technology for a special import approval using a dedicated dossier, with defined processing timelines. As a consolidated legal-review document, it does not create new obligations beyond rules already in force, but it is an important single-reference text for manufacturers, particularly foreign-invested enterprises, planning to import used machinery or used technology lines to expand or sustain production.

A state-owned enterprise signed a contract with the Ministry of Finance to carry out a science and technology task, with a fixed budget of VND 300 million payable upon completion and no invoice required. The contract was signed and completed in 2025, but the Ministry made payment in early 2026. The company ran into a problem because the new enterprise chart of accounts in Appendix II of Circular No. 99/2025/TT-BTC dated October 27, 2025 (effective from January 1, 2026) removed Account 161 - Non-business expenditure and Account 461 - Non-business funding sources, which had previously been used to record this type of funding. The Department of Accounting and Auditing Management and Supervision (Ministry of Finance) responded that, in substance, this is a sale-of-goods and service-provision transaction between the enterprise and the State, with the State acting as a customer, rather than a traditional budget-allocated non-business funding item. The enterprise should therefore rely on the signed science-technology task order contract and apply the revenue and expense recognition guidance in Circular 99/2025/TT-BTC to record the transaction appropriately, instead of looking for accounts equivalent to the abolished Account 161 and Account 461. This is an important reminder for state-owned enterprises and other entities with science-technology task or public-service order contracts with government agencies: from January 1, 2026, revenue from such contracts must be recorded as sales/service revenue under the new accounting regime, since the previous non-business funding accounts have been discontinued.

The Ministry of Finance responds to a question about e-invoice timing and required documentation for State Treasury payments in connection with drug procurement contracts by state-budget healthcare units. The question asks whether a seller may issue an invoice after acceptance/handover, when the purchasing unit has not yet received payment from the State Treasury. Per official guidance, the State Treasury disburses funds to budget-spending units upon receipt of the required documents under Decree No. 347/2025/ND-CP. The payment request file does NOT include invoices, acceptance records, or contracts. The State Treasury does not receive or verify these documents. Under State Budget Law No. 89/2025/QH15, the head of a budget-spending unit is responsible for ensuring lawful, efficient use of the budget and compliance with spending conditions. For specific guidance on investment project reporting procedures and forms, units should contact the competent investment registration authority directly.

The Department of Accounting and Auditing Management and Supervision (Ministry of Finance) clarified that Circular 99/2025/TT-BTC on enterprise accounting standards, effective from 1 January 2026, governs fiscal years starting on or after that date. For enterprises that had been pre-accruing major fixed asset repair costs but had not yet performed the repairs when the Circular came into force: enterprises must stop further pre-accrual. When the actual repair is subsequently carried out, the enterprise offsets actual repair costs against the pre-accrued amount. Any difference between the pre-accrued amount and actual costs is allocated gradually to production and business expenses over future periods. There is no mandatory retrospective restatement of previously accrued amounts. This is important guidance for enterprises with significant fixed assets (factories, heavy equipment) that have been using the pre-accrual method for major repairs.

The Tax Department provided guidance on VAT policy for businesses producing and trading in minimally-processed plant products (wood chips, ground bark, firewood, etc.) sold to other businesses, under VAT Law No. 48/2024/QH15 and Decree 181/2025/ND-CP (as amended by Decree 359/2025/ND-CP). Under newly inserted Clause 1b of Article 4 of Decree 181/2025: enterprises and cooperatives that purchase minimally-processed agricultural/forestry products and sell them to other enterprises/cooperatives are **not required to declare or pay VAT** but **may still claim input VAT credits**. If sold to individuals, household businesses, or other non-enterprise entities, the 5% VAT rate applies. Regarding VAT refunds: refunds are available only if conditions in Article 15 of the VAT Law are met (primarily exports, new investment projects, or businesses exclusively supplying 5%-rate goods with uncredited input VAT of VND 300 million or more after 12 months/4 quarters). If refund conditions are not met, uncredited input VAT may be treated as a **deductible expense** for CIT purposes under Article 9(2) of CIT Law No. 67/2025/QH15.

The tax authority (An Giang Province Tax Sub-department 9) confirmed that household businesses (HKDs) that already filed Q1/2026 quarterly tax returns under the old threshold but now have annual revenue under VND 1 billion (qualifying as non-filing businesses under the new rules) do **not need to continue filing quarterly tax returns**. No procedure to cancel the filed return or amend it to show zero revenue is required — the tax authority does not demand this. Instead, HKDs need only submit a **Revenue Notification using Form 01/TKN-CNKD** by no later than 31 January 2027. This is important practical guidance for small household businesses following the government's increase of the tax-exempt revenue threshold to VND 1 billion per year, reducing administrative tax burdens for millions of household businesses.

The Ministry of Finance provided guidance on VAT for companies purchasing wood by-products (ground bark, chipped bark, chipped acacia firewood, wood chips, etc.) from non-business individuals and reselling them to other enterprises for use as boiler fuel. Under VAT Law No. 48/2024/QH15 (amended by Law 149/2025/QH15) and Decree 181/2025/NĐ-CP (amended by Decree 359/2025/NĐ-CP effective January 1, 2026): Plantation/forest products not processed into other products or only minimally processed (including cutting, chopping, grinding, drying) are VAT-exempt when sold by the producing organization or individual. When a company purchases and resells to another enterprise: no VAT declaration or payment required. When sold to individual business households or other organizations/individuals: 5% VAT rate applies. Business households using direct calculation method when selling commercially: 1% rate on revenue.