Knowledge base

Decree 236/2025/ND-CP, effective from October 15, 2025, provides detailed regulations on the application of supplementary corporate income tax (CIT) under Pillar Two of the Global Anti-Base Erosion (BEPS 2.0) framework proposed by the OECD. This Decree implements National Assembly Resolution 107/2023/QH15, ensuring that large multinational enterprise (MNE) groups pay a minimum effective tax rate of 15% globally. The Decree applies to multinational groups with consolidated global revenue of at least 750 million Euros in at least 2 of the 4 consecutive fiscal years prior. Entities within these groups operating in Vietnam must comply with supplementary tax rules if their effective tax rate falls below 15%. For small and medium-sized enterprises (SMEs) not part of such large groups, this Decree has no direct impact. The Decree details methods for determining qualifying income and taxes, calculating effective tax rates, and mechanisms for collecting supplementary taxes (including the Income Inclusion Rule - IIR and Undertaxed Profits Rule - UTPR). Businesses must file GloBE Information Returns and Supplementary CIT Returns, with specific forms and guidance provided. The Decree also includes transitional rules and safe harbors to reduce compliance burdens during the initial implementation phase.

The Ministry of Finance provides guidance on the two-year Corporate Income Tax (CIT) exemption applicable to enterprises converted from household businesses under Law No. 67/2025/QH15. The law takes effect from 1 October 2026 and applies from the 2025 tax period onward. To determine eligibility, the tax authority directs enterprises to assess their actual circumstances against the requirements set out in Decree No. 320/2025/ND-CP dated 15 December 2025, which provides detailed guidance for implementing the CIT Law.

Decree 254/2025/ND-CP, issued by the Government on September 26, 2025, provides detailed regulations on the management, payment, and financial settlement of projects using public investment capital. This decree establishes clear procedures for disbursement, payment, and settlement of state budget capital for public investment projects, aiming to ensure transparency, efficiency, and accountability in public financial management. For SMEs participating in providing services, construction work, or supplying goods for public investment projects, this decree directly impacts contract payment and settlement procedures. Businesses need to understand documentation requirements, payment submission deadlines, and their responsibilities in providing valid supporting documents to receive timely payments. The decree also clearly defines the responsibilities of all parties involved in the payment and settlement process, helping to minimize payment delay risks. Understanding these regulations helps SMEs prepare accurate documentation and comply with proper procedures, thereby ensuring stable cash flow when participating in public projects. The decree takes effect immediately from the date of issuance, so businesses currently executing contracts with public investment projects need to review their internal processes to ensure compliance.

The State Bank of Vietnam (SBV) has issued Consolidated Document No. 13/VBHN-NHNN, merging Circular 19/2025/TT-NHNN (effective September 15, 2025) with its amending Circular 64/2025/TT-NHNN (effective February 15, 2026) into a single, unified set of rules governing the operating network of microfinance institutions (MFIs) - that is, their branches, transaction offices, representative offices, support units, and transaction points. Key content includes the financial conditions an MFI must meet to open a branch or transaction office (at least 12 months of operation, a Tier 1 capital-to-total-assets ratio of at least 10 percent, bad debt capped at 3 percent); a formula that caps the number of branches and transaction offices an MFI may operate based on its actual charter capital; a three-tier approval structure (the SBV Governor, the Department of Credit Institution Supervision, and SBV Regional Branches); and tight controls on transaction points, including a cap of VND 1.5 million per customer per day on voluntary cash deposits. This document mainly affects microfinance institutions themselves - lenders that serve poor and near-poor households and micro-enterprises. General SME owners and household businesses are not directly bound by it, but should be aware of it if they borrow through a microfinance channel or partner with a local MFI, since it shapes how widely and how quickly those institutions can expand or contract their branch networks.

Decree 225/2025/ND-CP, effective from August 15, 2025, amends and supplements detailed regulations on investor selection under the Bidding Law. This document modifies previous decrees to improve the legal framework for bidding, creating a clearer legal basis for the investor selection process in public investment projects and state-funded projects. This decree affects businesses participating in investment project bidding, especially enterprises in construction, infrastructure, and PPP (public-private partnership) projects. Changes in procedures, bidding documents, evaluation criteria, and responsibilities of participating parties will directly impact how businesses prepare for and participate in bidding processes. For SME businesses, understanding the new regulations on investor selection is important if they wish to participate in public investment projects or cooperate with the state. Changes in administrative procedures, financial and technical capacity requirements, and document evaluation methods will require businesses to update internal processes and ensure full compliance to increase their chances of winning bids.

The National Assembly Office has issued Consolidated Text No. 114/VBHN-VPQH, merging the full Law on Value Added Tax (VAT) No. 48/2024/QH15 (effective July 1, 2025) with three subsequent amendments: Law No. 90/2025/QH15, Law No. 149/2025/QH15 (effective January 1, 2026), and Law No. 09/2026/QH16 (effective April 24, 2026). This is the complete, up-to-date version of the VAT Law that businesses, accountants, and household businesses should use for reference instead of the original 2024 text. Main content covers: the scope of taxable objects and 28 categories of goods and services exempt from VAT (unprocessed farm produce, life insurance, medical services, textbooks, software, land-use-right transfers, and more); three tax rates of 0 percent, 5 percent, and 10 percent; two tax calculation methods (the credit method and the direct-on-revenue method); conditions for input VAT deduction and refund; and prohibited acts related to invoices and documentation. Key points for SME owners and household businesses: the annual revenue threshold below which household and individual businesses are exempt from VAT (Article 5, Clause 25) has been amended twice and is now set by the Government for each period; e-commerce platforms and digital platforms with payment functions must withhold, declare, and pay VAT on behalf of household and individual sellers using the platform; foreign suppliers selling goods or digital services through e-commerce channels to customers in Vietnam are subject to the 10 percent rate. The refund threshold for un-deducted input VAT is 300 million VND for exports and investment projects. Because this is a consolidated text rather than a new law, its provisions took effect on the dates listed above at different times; businesses should match each clause to its corresponding effective date when applying it.

Tax Sub-department No. 10 of Dong Nai province clarifies the VAT treatment for cashew shell residue (a by-product recovered when pressing oil from cashew shells). From 1 July 2025 to 31 December 2025: enterprises and cooperatives using the VAT credit method that sell cashew shell residue to other enterprises or cooperatives must apply the standard VAT rate of 10%. From 1 January 2026 (when Law No. 149/2025/QH15 takes effect): enterprises and cooperatives using the VAT credit method that sell cashew shell residue to other enterprises or cooperatives are NOT required to declare or pay VAT on these sales.

The Ministry of Finance (through Can Tho City Tax Department) confirmed that self-manufactured tools such as scaffolding frames, diagonal braces, and similar equipment produced by a construction company and transferred to project sites for construction use qualify as internal goods in circulation to continue the production process. Under Clause 1, Article 6 of Decree 181/2025/ND-CP, such goods are excluded from VAT liability. The tax authority confirmed that the company is not required to issue an invoice and is not required to declare or pay VAT on the internal transfer of these self-manufactured tools. Earlier audit positions requiring invoice issuance (even without VAT) were found inconsistent with the applicable regulations.

The Ministry of Finance provides guidance on VAT treatment of wood and wood products effective 1 July 2025 under VAT Law 48/2024/QH15 and Decree 181/2025/ND-CP. The key point: wood is explicitly excluded from the 5% VAT group applicable to minimally processed agricultural and forestry products; processed wood and commercially traded wood is subject to 10% VAT. Specifically: self-produced minimally processed forestry products sold by the producer are VAT-exempt. However, wood (even minimally processed) does **not qualify for the 5% rate** because the new law explicitly excludes wood from that category. Commercially traded or further-processed wood products attract **10% VAT**. On 13 April 2026 the Ministry of Finance issued Official Letter 4582/BTC-CST providing detailed guidance on VAT treatment of minimally processed wood to provincial and city tax departments.