Many enterprises accrue the Tet bonus into the old year’s costs but only pay the money after 31 March of the following year — and at finalisation the accrual is disallowed entirely because it was not actually spent in the tax year, while employees’ personal income tax is redetermined into the payment year. This article explains the two-layer mechanism, the possibility of rescuing a bonus already paid, and how to rewrite the bonus policy so the problem does not repeat.
Why payment after the finalisation point is disallowed
The deduction principle of the Corporate Income Tax Law 67/2025/QH15 is that a cost must actually arise in the tax period and be fully documented. A Tet bonus decided by the board at the old year’s end but paid in cash afterwards is an accrual not yet actually spent at the closing date: at the old year’s finalisation, the tax authority disallows the accrual because, when taxable income is determined, the enterprise has not actually disbursed and the payment obligation has not been performed. The cost is not lost forever — it is examined as a cost of the year of actual payment if conditions are met — but it is deferred, and if the old year enjoyed a tax incentive, the deferral causes real damage.
The second layer belongs to the recipients’ personal income tax: under the Personal Income Tax Law 109/2025/QH15 (applying from 1 July 2026), employment income is taxable when the payer pays it. A bonus decided in the old year but paid in April of the next is taxable income of the next year, not the old one; the enterprise withholds by payment year. An enterprise that withheld and finalised for employees in the old year faces redetermination, dragging with it corrected withholding certificates for a whole roster of individuals — the heaviest administrative part of this incident.
Rescuing a paid bonus and fixing the bonus policy
For a bonus actually paid after 31 March, the main rescue route is to book the cost into the year of actual payment: the enterprise files a supplementary adjustment removing the accrual from the old year (if it was included) and recognises it in the payment year’s finalisation, with the full document set of bonus decision, recipient list and bank payment records. Note also the welfare cap: total welfare-type spending paid directly to employees — including festive and Tet bonuses — must not exceed one month of the average salary actually paid in the tax year; the excess over the cap is disallowed permanently rather than deferred, so when booking into the payment year the cap of that year must be rechecked.
Fixing the bonus policy is prevention for later years, in three points: the financial regulations or collective labour agreement must state the conditions, source and timing of the bonus so the cost has a documentary basis from the year’s start; the payment schedule should close before the finalisation cut-off of the earning year, or the enterprise accepts and proactively books the cost in the payment year instead of accruing; and the PIT withholding process must key to the actual payment date on bank records, not to the date the bonus decision was signed. Enterprises with a fiscal year different from the calendar year should map these points to their own accounting period, because 31 March is only the expression of the tax-period principle, not a fixed date for every business.
Conclusion and recommendations
The late Tet bonus incident repeats every year at many enterprises because it sits at the junction of HR planning and the tax period. The thorough fix is to synchronise three calendars: the bonus decision calendar, the payment calendar and the finalisation calendar must be designed together from the start of the fourth quarter. We recommend reviewing the current bonus policy and the coming Tet payment schedule now; if payment must fall after the finalisation period, book the cost in the payment year from the outset and inform employees in advance about the PIT year of their bonus to avoid internal disputes.
Frequently asked questions
1. Why is payment after 31/3 disallowed?
Because at the finalisation of the tax year the bonus had not been paid in real money: the board had only decided the policy, the enterprise had not disbursed, so the advance accrual fails the actually-incurred condition the Corporate Income Tax Law 67/2025/QH15 requires. The disallowance typically surfaces when the enterprise files the old year’s finalisation while the payment documents carry next year’s dates. It is a timing error, not a defect in the bonus itself — the payment remains valid if it is genuinely employee income and fully documented when paid.
2. Can a bonus already paid be rescued as a cost?
Yes, by moving it to the right period: a bonus actually paid is recognised as a cost of the year of actual payment, with the complete bonus decision, signed recipient list and bank payment records; and the enterprise amends the old year’s finalisation to remove the accrual if it was previously included. Two limits to remember: total direct welfare spending for employees remains capped at one month of the payment year’s average actual salary, with any excess disallowed outright; and if the old year was a tax holiday or reduction year while the payment year is not, the loss from the timing shift has no compensation mechanism.
3. Which year does the PIT fall into?
It falls into the payment year. Under the Personal Income Tax Law 109/2025/QH15, the tax point for employment income is when the organisation or individual pays the income; a bonus decided at the old year’s end but paid early the next year is income of the next year, aggregated into that year for withholding and finalisation. An enterprise that withheld wrongly in the old year must correct the withholding certificates and support employees in re-finalising in the correct year, avoiding double counting of the same income in both years.
4. What should the bonus policy change?
The bonus policy needs four changes: state clearly the assessment basis, funding source and expected payment time so the cost has a documentary foundation; tie the payment calendar to the tax period — pay before the earning year’s finalisation cut-off or default to booking in the payment year; set the aggregate welfare cap by average monthly salary so the ceiling is not breached; and separate the bonus decision from the payment document, requiring every payment to run through the bank with the payment date as the PIT withholding basis. Fixing this once in the policy is cheaper than handling it as an incident every year.
This article has been quality-reviewed by the FLAW AI Legal Council