Vietnam CIT 2026: New Guidance Documents and 6 Key Points

Short answer: As of 14/10/2026, Vietnam’s corporate income tax (CIT) guidance framework has four tiers: Law 67/2025/QH15 (effective 01/10/2025, applicable to tax year 2025) → Decree 320/2025/ND-CP (15/12/2025) → Decision 517/QD-BTC correction (20/3/2026) → Circular 20/2026/TT-BTC (12/3/2026). Key points: progressive rates of 15%/17%/20% by revenue (no more “flat 20%”); the cashless-voucher threshold tightened to VND 5 million; quarterly provisional payments of at least 80%; capital transfers by foreign investors taxed at 2% of transfer value.

1. Document map: the four-tier CIT guidance pyramid

Tier	Instrument	Date/effect	Role
1. Law	Law 67/2025/QH15 (passed 14/6/2025)	Effective 01/10/2025, applicable to tax year 2025; replaces Law 14/2008	Rate framework, taxpayers, new incentives
2. Decree	Decree 320/2025/ND-CP	15/12/2025	Detailed implementation guidance
3. Correction	Decision 517/QD-BTC	20/3/2026	Corrects Decree 320/2025
4. Circular	Circular 20/2026/TT-BTC	12/3/2026	Guides Law 67/2025 + Decree 320/2025

Consolidated text: VBHN 113/VBHN-VPQH. Read the pyramid top-down — a Circular may not contradict its Decree, nor a Decree its Law.

2. Six key changes businesses must know

2.1. Progressive 15%/17%/20% rates by revenue

The biggest change: the standard CIT rate is no longer a flat 20%, but progressive by revenue:

15%: enterprises with revenue of VND 3 billion or less;
17%: revenue above VND 3 billion up to VND 50 billion;
20%: all other cases (the standard rate).

Do not plan 2026 taxes on a “flat 20%” assumption — small and medium enterprises enjoy materially lower rates.

2.2. Cashless-voucher threshold: VND 5 million

The invoice/voucher threshold requiring non-cash payment for deductible expenses has been tightened from VND 20 million to VND 5 million. Invoices of VND 5 million or more paid in cash will be disallowed — accountants must review the entire payment workflow.

2.3. Provisional payments: at least 80% over 4 quarters

Total CIT provisionally paid over the 4 quarters must reach at least 80% of the annual finalization amount. Underpayment may attract late-payment interest on the shortfall — see our analysis of the new quarterly CIT provisional payment rules.

2.4. Foreign-investor capital transfers: 2%

Income from capital transfers by foreign investors is taxed at 2% of the transfer value — even on loss-making transfers. FDI companies and investment funds must price this into M&A deals.

2.5. Restructured incentives

The CIT incentive system is reorganized under Law 67/2025 and Decree 320/2025, with more detailed rules on qualifying objects, conditions and exemption/reduction periods. Companies enjoying legacy incentives must check the transition provisions to avoid “falling off” their incentives.

2.6. Decree 141/2026/ND-CP: new CIT exemption now in force

Decree 141/2026/ND-CP (issued 29/4/2026, effective from 01/01/2026): amends and supplements Decree 320/2025/ND-CP — introducing a CIT exemption for enterprises with total annual revenue of VND 1 billion or less; it also amends Decree 68/2026, raising the tax-exempt threshold for household businesses to VND 1 billion. Small businesses should check eligibility for this new exemption when finalizing their returns.

3. Common risks in 2026 finalization

Risk 1: Still applying 20% to sub-VND 3 billion revenue companies — overpaying and hurting cash flow;
Risk 2: Paying cash for invoices of VND 5 million or more — expenses disallowed, tax up;
Risk 3: Provisional payments below 80% — late-payment interest;
Risk 4: Ignoring Correction Decision 517/QD-BTC — applying the pre-correction version of Decree 320/2025;
Risk 5: Missing the new CIT exemption under Decree 141/2026/ND-CP — enterprises with total annual revenue of VND 1 billion or less may be exempt from CIT but fail to apply it at finalization.

Frequently asked questions

What are the 2026 CIT rates?
15% (revenue ≤ VND 3B), 17% (revenue VND 3–50B), 20% (standard) — under Law 67/2025/QH15.

From what amount is non-cash payment mandatory?
VND 5 million or more (tightened from 20 million).

What is the minimum provisional payment?
80% of the annual finalized tax over 4 quarters.

What tax applies to foreign-investor capital transfers?
2% of transfer value, even at a loss.

Sources

Law on Corporate Income Tax 67/2025/QH15 (passed 14/6/2025, effective 01/10/2025, applicable to tax year 2025; replacing Law 14/2008); consolidated VBHN 113/VBHN-VPQH;
Decree 320/2025/ND-CP (15/12/2025) and Decision 517/QD-BTC (20/3/2026, correction);
Circular 20/2026/TT-BTC (12/3/2026) guiding Law 67/2025 and Decree 320/2025;
Decree 141/2026/ND-CP (issued 29/4/2026, effective from 01/01/2026): amends and supplements Decree 320/2025 — CIT exemption for enterprises with total annual revenue of VND 1 billion or less; amends Decree 68/2026, raising the tax-exempt threshold for household businesses to VND 1 billion.

Note: Updated as of 14/10/2026; Decree 141/2026/ND-CP (effective from 01/01/2026) has introduced a CIT exemption for enterprises with total annual revenue of VND 1 billion or less — verify current texts before applying.

Does your company need a 2026 CIT health check or revenue-based rate optimization? Contact FLAT Law Firm for advice.

Transparency note: This article was drafted by the FLAW AI Legal Council (an AI panel) and is not a substitute for advice from a licensed lawyer on your specific case.

This article is awaiting QA Council review.