Foreign Investment

Circular 20/2026/TT-BTC on CIT: Key Points Businesses Should Know

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On 12 March 2026, the Minister of Finance issued Circular 20/2026/TT-BTC detailing certain articles of the 2025 Law on Corporate Income Tax and Decree 320/2025/ND-CP — and this Circular 20/2026 CIT Vietnam guidance is the document corporate tax teams will reach for most often in the coming finalization season. The Circular is effective from 12 March 2026 and applies from tax year 2025. If the ten-point analysis of the CIT Law 67/2025 mapped the new legal framework, and the Decree 320/2025 analysis covered the operational rules at decree level, Circular 20 answers the more practical questions: what dossiers, what timing, what forms, and what procedures. Below are the key points businesses — especially FDI enterprises — need to know.

Contents

1. Overview {#1-overview}

Full title: Circular No. 20/2026/TT-BTC dated 12 March 2026 of the Minister of Finance detailing certain articles of the Law on Corporate Income Tax and Decree No. 320/2025/ND-CP dated 15 December 2025 of the Government detailing certain articles of and measures to organize the implementation of the Law on Corporate Income Tax.

Scope (Article 1) covers seven areas:

  1. Dossiers for deductible expenses under points b and c, clause 1, Article 9 of the Law on Corporate Income Tax;
  2. Dossiers for tax incentives under Articles 4, 13, 14 and 15 of the Law on Corporate Income Tax;
  3. Timing for determining CIT-liable revenue in certain cases under point c, clause 2, Article 8 and clause 3, Article 12 of Decree 320/2025/ND-CP;
  4. Declaration and payment dossiers of Vietnamese enterprises investing abroad, for income from offshore investment projects (clause 2, Article 12 of Decree 320/2025/ND-CP);
  5. CIT for foreign enterprises doing business in Vietnam (Article 2, clause 4 Article 3, and clause 3 Article 12 of Decree 320/2025/ND-CP);
  6. Registration of investment capital for enterprise expansion projects (Article 20 of Decree 320/2025/ND-CP);
  7. Tax obligations where fixed assets formed from the enterprise Science and Technology Development Fund are transferred to production/business use, and the Fund appropriation and utilization report form (clause 4, Article 22 of Decree 320/2025/ND-CP).

Effectiveness and replaced regulations (Article 10):

  • Effective: 12 March 2026; applicable from tax year 2025 (clause 1, Article 10).
  • Replaces in full: Circular 78/2014/TT-BTC and Circular 96/2015/TT-BTC (clause 6, Article 10) — the two most familiar CIT guidance documents of the past decade-plus are now expired.
  • Repeals CIT-policy provisions in (clause 7, Article 10): Articles 1, 2, 7, 10, 13 (except point b.11, clause 1, Article 13) and Article 16 of Circular 103/2014/TT-BTC (foreign contractor tax); Article 6 of Circular 119/2014/TT-BTC; Chapter I of Circular 151/2014/TT-BTC; Article 5 of Circular 130/2016/TT-BTC; Article 3 of Circular 25/2018/TT-BTC; Article 2, clause 5 Article 3, Article 4, and clause 3 Article 5 of Circular 67/2022/TT-BTC (on the Science and Technology Development Fund); Article 4 of Circular 83/2016/TT-BTC; and Article 4 of Circular 128/2011/TT-BTC.

Transitional provisions (clauses 2–4, Article 10) — read carefully:

  • Expenses arising before the Circular's effective date that Circular 96/2015/TT-BTC had specifically regulated on conditions and dossiers continue under Circular 96/2015 for tax year 2025. Expenses under Article 3 of Circular 20 not specifically regulated by Circular 96/2015 use invoices and vouchers under the law as their 2025 dossier.
  • The non-cash payment voucher rules and the capital transfer rules apply from the date Decree 320/2025/ND-CP took effect (i.e., 15 December 2025).
  • Contractor/subcontractor agreements currently applying the hybrid method under Circular 103/2014/TT-BTC, signed before this Circular's effective date, continue to determine CIT obligations under the regulations in force at the time of signing.

Circular 20's place in the new CIT framework: Law 67/2025 (effective 1 October 2025) sets the framework → Decree 320/2025 details the operational rules (VND 5 million threshold, 200% R&D super-deduction, contractor tax rates, incentives, effectiveness and transition) → Circular 20/2026 guides each dossier component, form and timing. Notably, Circular 20 closes several gaps the Decree 320/2025 analysis had to leave open: declaration dossiers for offshore-project income (Article 6), tax treatment of assets formed from the Science & Technology Fund plus the report form (Article 9), and CIT for foreign enterprises with full scope and computation detail (Article 7).

2. Key new points {#2-key-points}

2.1. Deductible-expense dossiers detailed per expense item (Article 3)

Article 3 — the Circular's longest — sets dossier components for all expenses under points b and c, clause 1, Article 9 of the 2025 CIT Law. General principles: expenses must be supported by sufficient invoices and vouchers plus the specified dossier components; dossiers may be originals, certified copies, company-stamped copies or electronic vouchers; enterprises must retain full dossiers for inspection and audit (clauses 14–15, Article 3).

Expenses under point b, clause 1, Article 9 — dossiers include:

  • b1 — national defense and security education, militia training: decision of the competent person in the enterprise + confirmation from the competent authority under sectoral law.
  • b2 — support for Party and socio-political organizations in the enterprise: establishment decision or working regulation + support request or approved funding plan (if any).
  • b3 — vocational education and training for employees: labor contract/collective labor agreement/financial regulation providing for training expenses (including where employees may pay by non-cash and be reimbursed non-cash by the enterprise) + training assignment decision + enrollment dossier (copy) + diploma/certificate or training institution confirmation/attendance list.
  • b4 — workplace HIV/AIDS prevention: internal regulation containing this expense item.
  • b5 — sponsorships: detailed by type (see section 2.2 on Form 01/TNDN).
  • b6 — scientific research, technology development, innovation, digital transformation: under the laws on science, technology and innovation, digital transformation, and Decree 320/2025/ND-CP.
  • b7 — losses from natural disasters, epidemics, force majeure not compensated: inventory record of lost assets/goods (value, cause, liability, type, quantity, unit price, recoverable value if any) + import-export-inventory statement certified by the legal representative + insurer compensation dossier (if any) + liability determination dossier (if any).
  • b8 — expenses for seconded personnel participating in governance of specially-controlled credit institutions or compulsorily transferred commercial banks: secondment decision + acceptance document + inter-party contracts/agreements (if any).
  • b9 — business expenses not yet matched with current-period revenue: nine sub-groups, many entirely new versus the old framework — unsuccessful bidding costs; market/product research and new product development costs that failed or were discontinued; land rental and infrastructure management/maintenance fees in economic zones, hi-tech zones, industrial parks/clusters (including State land leases) before the site enters production; depreciation/amortization allocation for leased assets during vacant periods; establishment costs for branches/business locations, post-suspension recovery, site restoration before dissolution; pre-sales product/service marketing; write-off of damaged, obsolete, expired or unsaleable inventory; write-off of damaged assets no longer needed; scrapping of waste and by-products from processing/manufacturing.
  • b10 — support for public works serving the enterprise's business: project approval document + investment decision or contract with the competent authority.
  • b11 — greenhouse gas emission reduction toward carbon neutrality and net zero, pollution reduction: competent-person decision + project/proposal dossier.
  • b12 — mandatory contributions to funds established by the Prime Minister or the Government: establishment decision/regulation + contribution confirmation record (if any).

What changed: Circulars 78/2014 and 96/2015 only specified dossiers for typical expenses; many expenses newly recognized by Law 67/2025 (net zero, credit-institution secondment, pre-sales marketing, inventory write-offs) previously had no uniform dossier guidance. Circular 20 fills the gap — which also means tax authorities will have a clear checklist during inspections; a missing dossier component risks disallowance.

2.2. Two new forms: 01/TNDN and 02/TNDN

  • Form 01/TNDN — Sponsorship confirmation record (point e, clause 5, Article 3): for sponsorship of education, healthcare, culture; disaster/epidemic relief; great-solidarity and gratitude houses and policy-beneficiary housing; sponsorship under Government/Prime Minister regulations for especially disadvantaged areas. The record must be signed by the enterprise representative (sponsor) and the recipient (or the fund-mobilizing organization). Special cases: sponsorship for patients requires confirmation from the fund-mobilizing organization plus the patient's or relative's signature; sponsorship for individuals (disaster/epidemic) requires the mobilizing organization's confirmation plus the recipient's signature; housing for policy beneficiaries requires the competent authority's confirmation of beneficiary status.
  • Form 02/TNDN — Goods/services purchase list (point a, clause 13, Article 3): for purchases of agro-forestry-fishery products from direct producers; handicrafts; scrap from direct collectors; household/individual assets; goods/services from individuals and business households below the VAT-liable revenue threshold. The list is signed by the legal representative or authorized person, who bears responsibility.

Unlike the old self-prepared lists, these forms are now issued uniformly with the Circular. Enterprises must switch to the new forms.

2.3. The VND 5 million non-cash threshold: three scenarios (clause 13, Article 3)

Law 67/2025 and Decree 320/2025 introduced the VND 5 million non-cash payment rule; Circular 20 turns it into three concrete dossier scenarios:

(a) Purchases from households/individuals (point a, clause 13): payment vouchers under accounting rules plus Form 02/TNDN. Key point: daily purchases from the same household/individual of VND 5 million or more must be paid non-cash — aggregated per day per seller, not per transaction.

(b) Employee-advanced purchases of VND 5 million or more (point b, clause 13): four dossier components — (i) invoices/vouchers under accounting rules; (ii) the enterprise's financial/internal regulation or decision authorizing employees to pay on its behalf; (iii) the employee's non-cash payment voucher for the authorized purchase; (iv) the enterprise's non-cash voucher reimbursing the employee. This is daily practice at FDI enterprises (urgent procurement, travel expenses), and the Circular demands two layers of non-cash evidence — missing either layer risks disallowance.

(c) Unpaid expenses of VND 5 million or more per transaction (point c, clause 13): deductible where there is a purchase contract + handover record; upon actual payment, a non-cash payment voucher is mandatory to preserve deductibility.

(d) Leasing assets from individuals (point d, clause 13): lease contract + rental payment vouchers. Where the contract states rent excludes taxes (VAT, PIT) and the enterprise pays tax on the individual's behalf under tax administration law, the withheld tax paid is also deductible if supported by tax payment vouchers — a favorable new point resolving a long-standing issue for enterprises leasing houses or warehouses from individuals.

2.4. Tax incentive dossiers: self-determination, self-declaration, self-responsibility (Article 4)

Procedures and dossiers for tax exemption, reduction, preferential rates and exemption/reduction periods (Articles 4, 13, 14, 15 of the 2025 CIT Law) follow tax administration law (clause 1, Article 4). Enterprises self-determine eligibility conditions, preferential rates, exemption/reduction periods and deductible losses for declaration and finalization with the tax authority (clause 2, Article 4). The Circular confirms: no pre-registration or pre-approval of incentives — but if inspection finds unmet conditions, the competent authority will assess back taxes, late-payment interest and penalties (clause 3, Article 4).

This continues the long-standing "self-declare — self-pay — inspect later" mechanism, but under the new incentive framework of Law 67/2025 (15%/17%/20% rates by revenue scale, new incentive groups), misjudging eligibility is a real risk. FDI enterprises currently enjoying incentives should re-verify their full eligibility dossiers — see investment incentives for foreign-invested projects in Vietnam and tax compliance for FDI companies.

2.5. Timing for determining CIT-liable revenue (Article 5)

For enterprises established under Vietnamese law (clause 1, Article 5):

ActivityCIT revenue timing
Exported goodsDate of ownership transfer under the export contract; if indeterminable, under customs law on the basis for identifying exported goods
Air transportCompletion of the transport service for the buyer
Construction and installation (including shipbuilding)Acceptance of the work, work item or construction/installation volume — regardless of whether payment has been received
Electricity and water supplyDate the meter reading is confirmed on the electricity/water bill

Most notable for FDI enterprises in construction and EPC: revenue is recognized at acceptance, irrespective of payment — directly affecting the tax year in which work-in-progress project revenue is booked.

For foreign enterprises (clause 2, Article 5):

  • Capital transfers: when the initial capital transfer contract takes effect;
  • Securities and deposit certificates: at transfer;
  • Derivatives (futures): at order matching on the Stock Exchange trading system or at futures contract maturity.

The capital-transfer timing rule (from the initial contract's effectiveness) matters greatly in M&A deals with long-lasting conditions precedent — sellers must book the income in the correct tax year.

2.6. Vietnamese enterprises investing abroad: dossiers per Circular 80/2021 (Article 6)

Declaration and payment dossiers for income from offshore investment projects (clause 2, Article 12 of Decree 320/2025/ND-CP) follow Circular 80/2021/TT-BTC guiding the Law on Tax Administration and Decree 126/2020/ND-CP (as amended).

This closes a gap the Decree 320/2025 analysis had to leave open (clause 2, Article 12 delegated guidance to the Ministry of Finance) — Circular 20 now designates the applicable instrument. Vietnamese groups expanding into Laos, Cambodia, Myanmar and beyond should align with Circular 80/2021's forms and deadlines when declaring offshore income.

2.7. CIT for foreign enterprises doing business in Vietnam (Article 7)

Article 7 is the Circular's second-heaviest provision, replacing the foreign contractor tax CIT rules previously scattered across Circular 103/2014/TT-BTC (fully repealed from 01/07/2026 under Article 99 of Circular 89/2026/TT-BTC). See our in-depth analysis of foreign contractor tax in contracts with foreign partners in Vietnam.

Scope (clause 1, Article 7): foreign enterprises under points b2, b3 and b4, clause 1, Article 2 of Decree 320/2025/ND-CP — including foreign contractors and sub-contractors with or without a permanent establishment in Vietnam, including e-commerce and digital-platform-based business, where they:

  • Do business in Vietnam or earn Vietnam-sourced income under contracts, agreements or commitments with Vietnamese organizations/individuals (or with foreign sub-contractors);
  • Supply services, services bundled with goods, or supply and distribute goods — including authorizing/engaging Vietnamese organizations or individuals to perform part of the distribution — via on-spot export/import or Incoterms, except processing with re-export for the foreign hirer. Applies only where the foreign contractor remains the goods owner, bears distribution/advertising/marketing/quality costs, or sets the selling price;
  • Supply goods with a delivery point inside Vietnam together with Vietnam-performed services (advertising, marketing, trade promotion, after-sales, installation, trial runs, warranty, maintenance — including free accompanying services), whether or not priced into the goods contract;
  • Negotiate and sign contracts in their own name through Vietnamese organizations or individuals;
  • Exercise export/import rights, distribute in the Vietnamese market, purchase goods for export, or sell goods to Vietnamese traders.

Exclusions (clause 2, Article 7):

  • Delivery at a foreign or Vietnamese border gate without Vietnam-performed services (even with seller warranty terms);
  • Repair services for vehicles, machinery and equipment performed abroad;
  • Advertising/marketing; investment and trade promotion; brokerage; training performed abroad — except services performed on the internet (advertising, promotion, brokerage) and online training;
  • International telecom/postal revenue sharing; use of bonded warehouses and inland container depots (ICDs) for international transport, transit, transshipment, storage and processing;
  • Other services performed abroad and not consumed in Vietnam;
  • Capital transfers as intra-group ownership restructurings not changing the ultimate parent and generating no income — deemed no-income where four cumulative conditions hold: no change of ultimate beneficial owner; transfer value not exceeding book value or initial contributed capital; no value difference under the restructuring dossier approved by the competent authority; the transferee inherits all capital value, obligations and rights of the transferor;
  • Sales of raw materials, supplies and components at bonded warehouses or non-tariff zones for import into Vietnam to manufacture export goods or process exports under contract; designation of an export-processing enterprise to deliver goods to another export-processing enterprise for export manufacturing/processing.

The intra-group restructuring exclusion is welcome news for multinationals regularly restructuring Vietnamese subsidiaries — but the four cumulative conditions demand tightly prepared restructuring dossiers (see section 5 on open points).

Computation (clause 3, Article 7): CIT payable = Taxable revenue × Percentage rate. Taxable revenue is all revenue received by the foreign contractor, before deducting taxes payable, including costs paid on the contractor's behalf by the Vietnamese party (if any). Where the contract excludes CIT payable, taxable revenue is grossed up: Taxable revenue = CIT-exclusive revenue ÷ (1 − Percentage rate).

Percentage rates (clause 5, Article 7, per clause 3, Article 12 of Decree 320/2025/ND-CP):

ActivityRate
Services5% (restaurant, hotel and casino management: 10%; services bundled with goods where values cannot be separated: 2%)
Supply and distribution of goods in Vietnam via on-spot export/import or Incoterms1%
Royalties10%
Leasing of aircraft, helicopters, gliders (including engines, spare parts) and sea vessels2%
Leasing of drilling rigs, machinery, equipment and means of transport5%
Securities transfers; outward reinsurance0.1%
Derivative financial services2%
Capital transfers2%
Construction, transport and other activities2%

Allocation rules for mixed contracts: inseparable values take the highest applicable rate; construction including materials/machinery supply that cannot be separated takes 2% on the whole contract value; machinery/equipment supply with Vietnam-performed services that cannot be separated takes 2%.

Versus Circular 103/2014, the rate framework is largely preserved, but the scope is visibly extended to e-commerce, digital platforms and modern distribution models (on-spot import/export, Incoterms, contracting in own name via Vietnamese intermediaries) — matching how business is actually done today.

2.8. Registering investment capital for expansion projects (Article 8)

When implementing an expansion project, the enterprise sends a written notice to its directly managing tax authority at the same time as filing the CIT finalization return, no later than the year the expansion project is implemented, advising the registered investment capital of the project (clause 1, Article 8). Any change to the registered capital during implementation must be re-notified (clause 2, Article 8).

This is a new procedural obligation tied to the expansion-project incentive regime under Article 20 of Decree 320/2025/ND-CP. FDI enterprises expanding factories or raising investment capital in 2026 should add this to the compliance checklist — late notification may affect proof of incentive eligibility for the expansion.

2.9. Assets formed from the Science and Technology Development Fund (Article 9)

Where fixed assets formed from the enterprise's Science and Technology Development Fund for R&D, not yet fully depreciated, are transferred to production/business use: the remaining value is booked to other income, while the same remaining value is depreciated as a deductible expense in determining taxable income (clause 1, Article 9).

Enterprises prepare the Fund appropriation and utilization report on Form 03-6/TNDN, Appendix II issued with Circular 80/2021/TT-BTC (clause 2, Article 9). Together with the repeal of the Fund rules in Circular 67/2022/TT-BTC, this is the new single point of reference for all Fund reporting obligations.

3. Practical impact on FDI enterprises {#3-impact}

First, supply chains from households and individuals. Many FDI enterprises in agro-forestry-fishery processing, scrap collection and handicraft inputs rely on household and individual suppliers without invoices. From now on, daily purchases from the same seller of VND 5 million or more must be non-cash, with Form 02/TNDN. Procurement at sourcing areas — where sellers are used to cash — will need time and a transition plan (bank transfers, identified e-wallets).

Second, employee-advanced payments. Daily practice at FDI enterprises (urgent procurement, travel expenses). The Circular requires four dossier components, including two layers of non-cash vouchers (the employee's and the enterprise's reimbursement). Enterprises without a financial regulation on employee advances should issue one immediately — otherwise the entire expense risks disallowance at finalization.

Third, EPC, construction and foreign contractor agreements. The "acceptance triggers revenue, regardless of payment" rule, combined with the detailed contractor tax framework in Article 7, requires legal and tax teams to re-review all foreign contractor agreements: correct taxpayer identification, rates, withholding/filing obligations, and gross-up/net pricing clauses. See the tax risk checklist for companies in Vietnam.

Fourth, expansion projects. The new capital-registration notice, due with the finalization return no later than the implementation year, is entirely new; investment and accounting teams must coordinate so the deadline is not missed.

Fifth, R&D, innovation, net zero and sponsorship spending. The new dossier framework is both an opportunity (many expenses recognized for the first time) and a challenge (dossiers scrutinized more closely). Enterprises with ESG and carbon-neutrality strategies should prepare project/proposal dossiers from the outset rather than regularizing afterwards.

4. Action items and deadlines {#4-actions}

  1. Review all expenses under points b and c, clause 1, Article 9 of Law 67/2025 against each dossier component in Article 3 of Circular 20 — complete before the 2025 CIT finalization (filed in 2026).
  2. Move all payments of VND 5 million or more to non-cash — mandatory from 15 December 2025 (Decree 320/2025's effective date); pay special attention to employee advances and household/individual purchases.
  3. Issue or amend financial/internal regulations on authorizing employees to pay on the enterprise's behalf — do it now, as this is a mandatory dossier component.
  4. Switch to Form 01/TNDN for all sponsorships and Form 02/TNDN for household/individual purchase lists — retire self-prepared forms under the old rules.
  5. 2026 expansion projects: notify the registered investment capital to the directly managing tax authority with the CIT finalization return, no later than the implementation year; re-notify on any change.
  6. Fund-formed assets transferred to production/business: book remaining value to other income, depreciate as deductible expense; file the Fund report on Form 03-6/TNDN (Appendix II, Circular 80/2021/TT-BTC).
  7. New foreign contractor agreements from 12 March 2026: apply Article 7 of Circular 20 — identify the taxpayer, rates, withholding/filing duties and review pricing (gross-up) clauses. Old agreements under the Circular 103/2014 hybrid method: keep as under the regulations in force at signing, and retain method-registration dossiers.
  8. Enterprises with offshore-project income: prepare declaration and payment dossiers under Circular 80/2021/TT-BTC.

5. Open points to monitor {#5-open-points}

The following points lack full guidance or enforcement precedent; take a conservative approach and monitor further guidance. For specific cases, consult tax counsel before finalization.

  • Transitional boundary for tax year 2025. Clause 2, Article 10 distinguishes expenses "specifically regulated on conditions and dossiers" by Circular 96/2015 (continuing under Circular 96/2015 for 2025) from those "not specifically regulated" (2025 dossier = invoices and vouchers under the law). Which bucket a given expense falls into requires case-by-case comparison — enterprises and tax authorities may reasonably read it differently. Recommendation: build an expense-by-expense comparison table, keep explanatory files, and consult the directly managing tax authority in advance.
  • Identifying agreements "currently applying the hybrid method." Clause 4, Article 10 lets pre-effective-date contractor agreements under the Circular 103/2014 hybrid method continue under the regulations in force at signing. In practice, proving "hybrid method" status depends on the tax-method registration dossier the enterprise filed. Recommendation: retain registration documents, original contracts and filed returns.
  • Proving an intra-group restructuring "generates no income." The four cumulative conditions in point m, clause 2, Article 7 — particularly "no change of ultimate beneficial owner" and "transfer value not exceeding book value" — have no enforcement precedent on verification method. Recommendation: prepare the approved restructuring dossier, independent valuation and full before/after ownership charts.
  • The VND 5 million "per transaction" threshold. For employee-advanced and unpaid expenses, the Circular says "per transaction" without defining the splitting of one transaction into smaller payments. There is a plausible reading that splitting transactions to avoid the threshold would attract scrutiny. Recommendation: apply consistently with accounting vouchers and avoid artificial splitting.
  • Forms referencing Circular 80/2021. Offshore-income dossiers (Article 6) and Form 03-6/TNDN (clause 2, Article 9) both reference Circular 80/2021/TT-BTC — issued to guide the 2019 Law on Tax Administration. When the Law on Tax Administration 108/2025 takes effect on 1 July 2026, forms and procedures may be updated; monitor amendments to Circular 80/2021.
  • Sponsorship dossiers for scientific research, innovation and digital transformation. Point dd, clause 5, Article 3 cross-refers to the laws on science, technology and innovation, digital transformation, and Decree 320/2025 — inter-agency coordination in practice is not yet uniform. Recommendation: prepare beyond-minimum dossiers and seek advance consultation.

6. FAQs {#6-faq}

When does Circular 20/2026/TT-BTC take effect, and from which tax year does it apply? Effective from 12 March 2026, applicable from tax year 2025. The non-cash payment voucher and capital transfer rules apply from the date Decree 320/2025/ND-CP took effect (15 December 2025).

Are cash payments of VND 5 million or more deductible for CIT purposes? No. Three scenarios under Circular 20: (1) purchases from households/individuals — daily purchases from the same seller of VND 5 million or more must be non-cash; (2) employee advances of VND 5 million or more — both the employee payment and the company reimbursement must be non-cash; (3) unpaid expenses of VND 5 million or more per transaction — a non-cash voucher is mandatory upon actual payment.

What dossiers are required for purchases from farming households or individuals without invoices? Payment vouchers under accounting regulations and the purchase list on Form 02/TNDN issued with Circular 20/2026/TT-BTC, signed by the legal representative or authorized person. Daily purchases from the same household/individual of VND 5 million or more must be paid non-cash.

How are foreign contractor agreements signed before Circular 20 took effect, currently under the hybrid method per Circular 103/2014, treated? CIT obligations continue under the regulations in force at the time of signing (clause 4, Article 10). Retain the tax-method registration documents for inspection purposes.

Which regulations does Circular 20/2026 replace or repeal? It replaces Circulars 78/2014/TT-BTC and 96/2015/TT-BTC in full, and repeals CIT-policy provisions in parts of Circulars 103/2014, 119/2014, 151/2014, 130/2016, 25/2018, 67/2022, 83/2016 and 128/2011/TT-BTC.

Need a CIT compliance review for your business?

Circular 20/2026/TT-BTC introduces extensive new dossier and voucher requirements just ahead of the 2025 CIT finalization season. FLAT Law Firm's tax team supports FDI enterprises in reviewing deductible-expense dossiers, restructuring foreign contractor agreements and preparing for tax inspections. Contact our hotline 0988424851 for advice tailored to your case.

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References

  • Circular 20/2026/TT-BTC dated 12 March 2026 of the Minister of Finance detailing certain articles of the Law on Corporate Income Tax and Decree 320/2025/ND-CP.
  • Law on Corporate Income Tax 2025 (67/2025/QH15).
  • Decree 320/2025/ND-CP dated 15 December 2025 of the Government.
  • Circular 80/2021/TT-BTC dated 29 September 2021 of the Minister of Finance.
  • Circulars 78/2014/TT-BTC, 96/2015/TT-BTC, 103/2014/TT-BTC (expired / fully repealed from 01/07/2026).