Fintech taxation is most misunderstood at one point: not all financial revenue is exempt from value added tax, and the boundary between non-taxable credit granting and taxable payment intermediary services directly decides service pricing.
Legal basis to know
The Value Added Tax Law 48/2024/QH15, effective 1 July 2025, places credit granting by credit institutions in the group of services not subject to value added tax, while payment intermediary services supplied by a fintech company are taxable at the standard rate and the company must issue invoices and declare on its service fee revenue. On corporate income tax, the Corporate Income Tax Law 67/2025/QH15 applies the standard 20% rate to a fintech company’s income like an ordinary enterprise, with incentives possible if the enterprise or project is recognized as hi-tech, science and technology or in an encouraged location. Loan interest income of a finance company and service fee income are therefore taxed under two different natures within the same group.
How this applies in practice
The costliest error is the hybrid revenue model: a platform earning both service fees and credit spreads while accounting books them as one revenue type, leaving the VAT-taxable part under-declared. In the opposite direction, companies sometimes tax revenue that is non-taxable, inflating prices out of competitiveness. The right handling is separating revenue by nature right in product design and the invoicing system, and seeking tax authority guidance for hybrid models before operating at scale.
What to do now
- Separate revenue by nature in the accounting and invoicing systems: VAT-taxable service fees and non-taxable credit income must not be merged.
- Review hi-tech or science and technology incentive conditions if seeking corporate income tax incentives, instead of assuming fintech status qualifies automatically.
- Request written tax guidance for new hybrid revenue models before scaling, to avoid back taxes and late payment penalties later.
Frequently Asked Questions
Are payment intermediary services subject to VAT?
Yes, payment intermediary services are subject to value added tax under the Value Added Tax Law 48/2024/QH15 and the provider declares tax on fee revenue; the non-taxable rule applies only to credit granting by credit institutions and does not extend to payment service fees.
How are e-wallet service fees taxed?
E-wallet service fees are the wallet company’s service revenue, subject to value added tax at the standard rate when invoiced to customers or partners, and taxable for corporate income tax; money customers top up into wallets is not the wallet company’s revenue and is not taxed as such.
What tax incentives can a hi-tech fintech get?
A fintech company recognized as a hi-tech enterprise or a science and technology enterprise may receive corporate income tax incentives under the Corporate Income Tax Law 67/2025/QH15 for income from the incentivized activity; an unrecognized fintech applies the standard 20% rate like an ordinary enterprise.
This article has been quality-reviewed by the FLAW AI Legal Council