Knowledge base

Consolidated Document No. 09/VBHN-BKHCN merges Circular No. 01/2018/TT-BKHCN with amendments under Circular No. 58/2025/TT-BKHCN, setting out how the Ministry of Science and Technology organizes, manages, and funds the National Innovation Startup Ecosystem Support Scheme to 2025 (Project 844), approved under Decision No. 844/QD-TTg. The circular divides Project 844 tasks into five groups: national/ministerial/provincial science and technology tasks; annual and periodic tasks (training, communications, building accelerator and investor networks, organizing startup events, supporting incubators); IT application tasks (the national startup portal and startup database system); construction of concentrated startup service zones; and project management activities. It sets out detailed procedures for selecting lead implementing organizations (application dossiers, appraisal councils, funding review), contract signing and liquidation, and a five-tier classification of innovation startup experts by years of experience (under 3 years to 12+ years) used to set financial support rates. The main audience is startup support organizations and innovation startups (businesses under 5 years old) seeking access to state budget funding, plus the ministries, localities, and agencies that directly implement Project 844. This is an internal administrative document governing how startup-support funding is approved and disbursed - it does not impose tax, e-invoice, labor, or customs obligations that apply to businesses generally.

Consolidated Document No. 12/VBHN-BTC, issued by the Ministry of Finance on April 22, 2026, merges Circular No. 57/2021/TT-BTC with its two amending circulars (No. 69/2023/TT-BTC and No. 139/2025/TT-BTC) into a single reference text. It does not replace the three original circulars; it only sets out the roadmap for reorganizing the stock, bond, and derivatives trading markets between the Hanoi Stock Exchange (HNX) and the Ho Chi Minh City Stock Exchange (HOSE). Under the roadmap, by no later than December 31, 2026, HOSE will consolidate all stock trading (both listed shares and shares registered for trading), taking over shares currently listed or registered for trading at HNX. In turn, HNX will hand off its stock trading business to HOSE and focus on organizing the bond market (government bonds, listed corporate bonds, and privately placed corporate bonds) along with the derivatives trading market. The document also sets minimum charter capital thresholds for new listing applications at each exchange during the transition period (VND 120 billion at HOSE, VND 30 billion at HNX before July 1, 2025) and explains how pending listing or trading-registration applications are handled when a company's shares move between exchanges. The entities directly affected are the Vietnam Stock Exchange, HNX, HOSE, and public companies, listed organizations, and organizations registered for trading. Small and medium enterprises that are not listed or registered for trading on either exchange are generally not directly affected by this reorganization roadmap.

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.

The Ministry of Finance confirms that salary and wage payments of **VND 5 million or more per transaction** must be accompanied by **non-cash payment documentation** to qualify as a deductible expense for corporate income tax (CIT) purposes, effective from 15 December 2025 (the effective date of Decree 320/2025/ND-CP). What constitutes "non-cash payment documentation" is determined under Article 26 of Decree 181/2025/ND-CP dated 01/7/2025, implementing the VAT Law. This requirement applies under Article 9, clause C of Decree 320/2025/ND-CP and makes no distinction between wages and other goods/services payments. The authoritative reference is Official Letter 218/CST-TN dated 27/01/2026 from the Department of Tax, Fee and Charge Policy Management, Ministry of Finance.

The Ministry of Finance clarified that when employees purchase goods or services on behalf of a company, each individual transaction (each invoice) determines whether the non-cash payment requirement applies - not the aggregate reimbursement request. The VND 5 million threshold is assessed per purchase transaction, not per consolidated payment claim. Under Article 9.1(c2) of Decree 320/2025/ND-CP, if the company delegates an employee to purchase goods/services of VND 5 million or more per transaction and the employee pays using a non-cash method, the expense is deductible provided proper invoices and documentation exist and the company reimburses the employee by bank transfer. For individual invoices below VND 5 million, there is no mandatory non-cash payment requirement for that specific transaction. Companies must maintain internal financial regulations clearly authorising employee purchases, supported by the employee's non-cash payment records and the company's bank transfer records for the reimbursement.

The Ho Chi Minh City Tax Department responded to the inquiry of FP Vietnam Co., Ltd. (response ticket No. 261225-31) regarding whether wages paid in cash or in-kind are deductible for corporate income tax (CIT) purposes. The Tax Department stated that, in order to provide an accurate answer in accordance with applicable legal regulations and the specific circumstances of the company, the company should contact its directly managing tax authority for guidance. The HCMC Tax Department did not provide substantive guidance on the conditions for deductibility in this case and instead referred the matter to the competent local tax authority.

The Ministry of Finance confirms that under Article 9(3)(a) of Decree No. 262/2025/ND-CP dated 14 October 2025, the business lines of a science and technology (S&T) organization must align with the fields of activity stated in its S&T organization registration certificate issued by a competent authority. This means S&T organizations may not freely register business lines that fall outside the scope of their issued S&T certificate. Local business registration authorities have the power to reject non-conforming business lines. The rule is intended to ensure consistency between actual business activities and the stated purpose for which the S&T organization was established.

The Ministry of Finance clarified whether cash wage and salary payments to employees qualify as deductible expenses for corporate income tax (CIT) purposes under CIT Law 67/2025/QH15 and Decree 320/2025/ND-CP. A construction company pays workers between VND 11-22 million per month in three cash instalments (on the 10th, 20th, and 31st of each month), each payment below VND 20 million, supported by payroll sheets, timesheets, and cash vouchers. Under Decree 320/2025/ND-CP, salary and wage expenses are deductible for CIT if: actually paid, properly documented (payroll sheets, timesheets, cash payment vouchers), and stipulated in labour contracts or collective bargaining agreements. Applicable rules on non-cash payment thresholds must also be observed. The Ministry confirmed that cash salary payments with adequate documentation and compliant with labour, accounting, and tax regulations are deductible as reasonable business expenses. Enterprises must ensure compliance with non-cash payment regulations for applicable transaction thresholds.

The Ho Chi Minh City Tax Sub-department 2 advised that soft skills training in digital marketing and business management (industry code 8559) is VAT-exempt if it qualifies as "teaching and vocational training activities as regulated by the law on education and vocational education" under Article 5.13 of VAT Law 48/2024/QH15 and Article 4.7 of Decree 181/2025/ND-CP. Soft skills training centers may qualify as an "other center performing continuing education tasks" under Article 42.2 of Decree 125/2024/ND-CP (covering centers for knowledge enrichment, life skills, and workplace capacity building), or as a "vocational education institution" under Vocational Education Law 74/2014/QH13 - requiring the relevant registration certificate in either case. If the activity does not meet these conditions, the service is subject to 10% VAT (no preferential rate of 0%, 5%, or 8% applies). Businesses must self-assess against their actual circumstances and applicable law, bearing responsibility for accuracy under Article 17.2 of Tax Administration Law 38/2019/QH14.

The Hanoi Tax Department confirmed that a 10-employee company paying salary twice monthly in cash (first payment on the 15th, second at month-end, each via a separate cash voucher) may deduct both salary payments as expenses for corporate income tax (CIT) purposes, provided proper supporting documents exist. Under Law on CIT No. 67/2025/QH15 and Decree 320/2025/ND-CP, salary expenses are deductible when supported by a payroll sheet, attendance record, and individual cash payment vouchers. The key conditions are that the expense must actually be incurred, relate to business operations, and be backed by adequate documentation. The tax authority advised the company to verify its situation against applicable tax laws and, if further queries arise, to consult http://hanoi.gdt.gov.vn or contact its direct tax management office.

The Department of Accounting and Auditing Management and Supervision (Ministry of Finance) confirmed that industrial zone infrastructure enterprises subleasing state-leased land (where the state lease uses a lump-sum payment model) must determine the nature of their sublease contract — as asset rental (VAS 06) or service provision (VAS 14) — based on the contract terms, land law provisions, and actual circumstances. Revenue must be **allocated over the lease period** for operating leases rather than recognized in full upon receipt of payment. This is important revenue accounting guidance for industrial zone enterprises, affecting financial statement presentation and CIT declarations based on revenue actually earned each period.