On June 11, 2026, the General Department of Taxation issued Official Letter No. 3896/CT-CS providing guidance on the application of corporate income tax (CIT) incentives under Decree No. 20/2026/NĐ-CP. Notably, these incentives also apply to foreign-invested enterprises (FDI), as detailed below:
1. Latest CIT Incentives
- Incentive rate: Full exemption of 100% CIT for 03 consecutive years.
- Application period: Calculated continuously from the first year the enterprise is granted its initial Enterprise Registration Certificate (ERC).
2. Key Highlight: Applicability to FDI Enterprises. This is an important unified guidance from the tax authority, affirming equal treatment in the investment environment:
- FDI enterprises newly granted an ERC in Vietnam are fully eligible for the 03-year CIT exemption, similar to domestic enterprises.
- Conditions: Enterprises must fully meet the criteria for small and medium-sized enterprises (SMEs) under the Law on SME Support and Decree No. 80/2021/NĐ-CP, and must not fall under excluded cases.
Recommendation from VBK:
Enterprises are advised to proactively review criteria related to revenue, capital, labor, and the timeline stated in the ERC to optimize eligibility for this tax incentive. If you require assistance in assessing eligibility or implementing the incentive declaration procedures, please feel free to contact us for direct consultation with VBK experts.
📥 Reference Materials
Policy summary (prepared by VBK):
- Vietnamese version
- English version
- Japanese version
Original document:
- 📄 Download Official Letter No. 3896 dated June 11, 2026 — General Department of Taxation: here
