A – CORPORATE INCOME TAX

1. Regulations on global minimum tax declaration and payment from fiscal year 2024

The Government's Decree No. 236/2025/ND-CP dated August 29, 2025 detailing a number of articles of the National Assembly's Resolution No. 107/2023/QH15 dated November 29, 2023 on the application of additional corporate income tax in accordance with regulations to combat erosion of the global tax base.

Regulations to note on declaration and payment of the global minimum tax will apply from fiscal year 2024:

1. Taxpayers

Subjects: Incorporated units of multinational corporations with a consolidated turnover of at least EUR 750 million in at least 2 years of the 4 consecutive years preceding the fiscal year in which the tax liability is determined.

Exclusions: Excluded cases as prescribed in Resolution No. 107/2023/QH15 and specific cases are specified in detail in Article 3 of the Decree. For example, government organizations, international organizations, non-profit organizations, pension funds meet certain conditions.

2. Persons not liable to pay tax

• Excluded cases specified in Clause 3, Article 3 of the Decree, including listed organizations and units that meet the criteria for ownership and ancillary activities for excluded units.

• Units are excluded according to the provisions of Article 2 of Resolution No. 107/2023/QH15.

3. Tax calculation method

This Decree details the method of tax calculation according to two main mechanisms:

Qualified Minimum Supplementary Corporate Income Tax (QDMTT):

• Applicable to constituent entities with production, business activities and residence in Vietnam.

• The QDMTT amount is calculated according to the formula specified in Resolution No. 107/2023/QH15, based on the additional tax rate, the actual tax rate in Vietnam and the additional taxable profit.

• The actual tax rate is calculated by dividing the adjusted corporate income tax by the prescribed net income.

Minimum Taxable Income (IIR) Aggregate Regulations:

• Applicable to the supreme parent company, partly owned parent company, intermediate parent company in Vietnam holding ownership of the incorporated unit subject to low tax rates abroad.

• The amount of IIR tax is calculated as the amount of tax allocated from the additional taxes under the Global Minimum Tax Regulations of the constituents subject to low tax rates abroad in the fiscal year.

• Decree prescribing the priority order of application of IIR.

Liability Reduction:

The Decree stipulates cases of liability reduction in the international investment period, the transitional period, or when the foreign country has implemented the standard environmental planning.

4. Procedures for tax declaration and payment

Announcement

• The National Trust (or its assigned unit) must notify the tax authority of the constituent unit responsible for declaration and the list of constituent units subject to application, within 30 days from the end of the reporting fiscal year.

Tax Registration

• The designated constituent unit responsible for tax declaration must be registered.

• The registration dossier includes a declaration of registration/change of tax registration information (Form No. 01-DKTD-DVHT).

• Registration deadline: No later than 90 days from the end of the reporting fiscal year.

Tax declaration

• Tax declaration dossiers under the QDMTT and IIR include information returns, additional corporate income tax returns, explanations of the difference and other relevant documents.

• Deadline for submitting tax declaration dossiers: According to Clauses 1 and 2, Article 6 of Resolution No. 107/2023/QH15.

Tax Payment:

• The amount of SCT is paid into the central budget.

• The constituent unit responsible for declaration must pay tax in accordance with the law on tax administration.

Coin

• Declaration of information in the currency of preparation of the consolidated financial statements of the supreme parent company.

• Tax payment in Vietnam Dong (except for cases where payment is chosen in the currency used to prepare consolidated financial statements).

Note

• The Decree contains detailed provisions on determinants such as the residence of the constituent entity, how to determine income, expenses, assets, and necessary accounting adjustments.

• The tax examination, handling of late payment and sanctioning of tax-related administrative violations shall comply with the law on tax administration.

The Decree takes effect from October 15, 2025 and applies from fiscal year 2024.

Promulgated with: Appendix I on a number of terms according to the set of global minimum tax regulations of the Joint Cooperation Forum on Combating Tax Base Erosion and Global Profit Transfer; Appendix II on how to determine the factors for calculating additional corporate income tax under the anti-erosion of the global tax base; and Appendix III on tax declaration and payment forms.

B – VALUE ADDED TAX

1. In what categories are export goods production projects eligible for tax refund?

Official Letter No. 3611/CT-CS dated September 5, 2025 of the Department of Taxation on value-added tax.

The Department of Taxation notes that, regarding the VAT refund for investment projects, the Ministry of Finance has provided guidance in Official Letter No. 5559/BTC-TCT dated May 8, 2020.

Accordingly, in case the company implements an investment project (the project is divided into stages and items) to serve the production and trading of export goods (the proportion of export turnover accounts for more than 90% of the total revenue) and has an input VAT amount used for investment arising in the investment period, it is eligible for tax refund according to the provisions of the VAT law.

In case at the end of the investment period, the company generates export revenue, the VAT amount of purchased goods and services (including fixed assets) used for the production and trading of export goods shall be eligible for VAT refund for export activities as prescribed.

From July 1, 2025, the VAT refund for investment projects will be implemented in accordance with the new provisions in Clause 2, Article 15 of the VAT Law No. 48/2024/QH15 and Article 30 of Decree 181/2025/ND-CP.

2. Is input VAT incurred during the project trial run period considered for refund?

Official Letter No. 3577/CT-CS dated September 4, 2025 of the Department of Taxation on value-added policies.

According to the reply of the Department of Taxation, in principle, in case a business establishment has a new investment project, is in the investment stage, has an operation or commissioning, if the time of operation and commissioning is a criterion or stage according to the requirements of technical standards prescribed by specialized laws and is implemented according to the rights,  Specific obligations in the written agreement of the parties are that the operation and commissioning are jobs in the project implementation stage.

The Department of Taxation has requested local taxes to base themselves on current regulations on VAT refund and actual dossiers, accurately determine the input VAT amount of goods and services arising in the investment period for consideration and handling according to regulations and competence.

C – PERSONAL INCOME TAX

1. Guidance on the time to make PIT deduction vouchers according to Decree 70/2025/ND-CP

Official Letter No. 2807/DON-QLDN1 dated 28/8/2025 of Dong Nai Provincial Tax Guidance on PIT.

Tax of Dong Nai province instructs: in case the individual authorizes tax finalization, the PIT deduction document shall not be issued. For individuals who sign labor contracts for 03 months or more (not subject to tax finalization authorization), the Company only issues to individuals one tax withholding document in a tax year as prescribed in Clause 3, Article 1 of Decree 70/2025/ND-CP dated March 20, 2025 of the Government.

2. New points of partial progressive tax schedule according to the draft Law on Alternative Personal Income Tax

Article 10 of the draft dated 17/07/2025 of the Law on Alternative Personal Income Tax.

In the draft Law on Alternative Personal Income Tax, the partial progressive tariff on income from salaries and wages currently includes 7 tax levels that are being studied and redesigned in the direction of shortening and simpler. In which, it is proposed to reduce the tariff from 7 tiers to 5 tiers and expand the income range at each tier.

According to Article 10 of the draft Law on Alternative Personal Income Tax, there are 2 options for partially revising the progressive tax schedule as follows:

Option 1: Maintain the tax rates of 5%, 15%, 25%, 30%, 35%, applicable to the corresponding taxable incomes/month: up to 10 million, over 10-30 million, over 30-50 million, over 50-80 million and over 80 million VND.

Tax tiers	TNTT/month (million VND)	Income gap in each tax tier (million VND)	Tax Rate (%)
1	From 0 to 10	10	5
2	Over 10 to 30	20	15
3	Over 30 to 50	20	25
4	Over 50 to 80	30	30
5	Over 80	~	35

 

Option 2: Maintain the same tax rates but further widen the income gap. Specifically: up to 10 million, over 10-30 million, over 30-60 million, over 60-100 million and over 100 million VND.

Tax tiers	TNTT/month (million VND)	Income gap in each tax tier (million VND)	Tax Rate (%)
1	From 0 to 10	10	5
2	Over 10 to 30	20	15
3	Over 30 to 60	30	25
4	Over 60 to 100	40	30
5	Over 100	~	35

 

One of the biggest and most far-reaching changes in this draft is the partial progressive tax reform. Instead of the current 7 levels, the drafting agency proposed two options and both were shortened to 5 levels.

Above are all the new points about the partial progressive tariff in 2025 according to current regulations and the draft Law on Alternative Personal Income Tax.

D – TAX DECLARATION – PAYMENT

1. Procedures for tax declaration, finalization and refund apply from September 3, 2025

Decision No. 3078/QD-BTC dated September 3, 2025 of the Ministry of Finance on the announcement of amended and supplemented administrative procedures in the field of tax administration under the management of the Ministry of Finance.

This Decision replaces 104 administrative procedures in the field of tax administration based on the provisions of Circular 40/2025/TT-BTC, including: CIT finalization declaration; PIT declaration for organizations and individuals declaring on their behalf; VAT refund; declaration of VAT, PIT, and CIT from the exploitation of collateral; declaration of land rent,  water surface rental; exemption and reduction of agricultural land use tax and non-agricultural land use tax; tax declaration for business households; declaring VAT by the deduction method for production and business activities; declaration of VAT by the method of direct revenue; SCT declaration; declaring CIT from real estate transfer activities; additional declaration of tax declaration dossiers; declaring environmental protection tax; declaration of severance tax; declare license fees; declaration of environmental protection fees; declaration of registration fee; declaring PIT from salaries and wages; declaration of PIT finalization from salaries and wages; registration of dependents for family circumstance deduction; PIT declaration from inheritance, transfer of contributed capital, transfer of securities; declaring PIT from business; declaring PIT from real estate transfer; VAT refund for investment projects; VAT refund for exported goods and services; tax registration;...

The Decision takes effect from the date of signing for promulgation.

Amending Decision No. 1474/QD-BTC dated April 24, 2025; Decision No. 1462/QD-BTC dated 22/7/2022; Decision No. 155/QD-BTC dated 24/01/2025.

2. The VAT amount in February and CIT in the 1st quarter of 2025 that have been extended to be paid in September

Notice No. 5735/TB-HCMC dated 26/8/2025 of Ho Chi Minh City Tax on the issuance of a notice of extension of payment of excise tax, value-added tax, corporate income tax, personal income tax and land rent in 2025.

Ho Chi Minh City Tax notes that, according to the regulations on extension of VAT and CIT payment in 2025 in Decree 82/2025/ND-CP, the VAT amount of the tax period in February 2025 must be paid no later than September 20, 2025 and the temporarily paid CIT amount in the first quarter of the tax period of 2025 must be paid no later than September 30, 2025. Enterprises need to pay on time to avoid violations.

For the remaining tax payment periods, it is prescribed as follows:

- No later than 20/11/2025 for SCT amounts of the tax periods of February, March, April, May and June 2025 for domestically manufactured or assembled automobiles (according to Decree No. 81/2025/ND-CP).

- No later than October 20, 2025 for VAT amounts of the tax period of March and April 2025; no later than 20/11/2025 for the VAT amount of May; no later than December 20, 2025 for the VAT amount of June; no later than October 31, 2025 for VAT amounts of the first quarter and no later than December 31, 2025 for VAT amounts of the second quarter.

- The temporarily paid CIT amount in the second quarter of 2025 shall be extended by 05 months from the end of the tax payment deadline as prescribed (i.e. payable no later than December 30, 2025).

- Land rent in 2025 (the amount payable in the first period of 2025) is extended for 06 months, from May 31, 2025 (i.e. must be paid no later than November 30, 2025).

- No later than December 31, 2025 for VAT and PIT payable in 2025 of business households and individuals.

3. The Department of Taxation introduces a set of 3 electronic handbooks to support taxpayers

On 07/09/2025, the Department of Taxation issued electronic manuals to guide taxes for business owners, chief accountants and business individuals. The e-Handbooks are integrated with AI to support taxpayers in asking and answering, helping to look up and apply tax policies, and apply tax administrative procedures quickly and conveniently.

Implementing the spirit of Resolution 57, most recently, on the basis of studying the tax law system and tax administration practices, the Department of Taxation has researched and issued a set of 3 electronic manuals, including:

Book 1:  An e-Tax Handbook for Business Owners

Book No. 2: Electronic Tax Handbook for Chief Accountants

Book No. 3: Electronic Tax Handbook for Business Individuals

The set of 03 electronic tax handbooks is designed in electronic form, easy to look up on many platforms. At the same time, integrate links to legal documents, declaration forms, instructional videos; The intuitive, infographic design makes it accessible even to beginners. To be a reliable companion of the business community and business households.

The set of 03 electronic tax handbooks is an important step in the process of modernizing the tax industry, demonstrating the determination of tax authorities to:

Firstly, accompanying, supporting and facilitating taxpayers.

Second, transparency, publicity, and easy access to tax law policies.

Third, encourage voluntary compliance, contributing to building a healthy business environment and sustainable development.

With the launch of 03 electronic tax manuals, the tax sector hopes and believes that this will be a bridge of tax knowledge closer to businesses, chief accountants and business households; at the same time, affirming the determination of the tax sector to innovate, reform and integrate.

Notably, it is a set of 3 electronic handbooks integrated with AI to support useful questions and answers, helping to look up and apply tax policies, and apply tax administrative procedures quickly and conveniently.