Decree No. 320/2025/ND-CP dated December 15, 2025 of the Government detailing a number of articles and organizational measures, and providing guidance on the implementation of the Law on Corporate Income Tax.
Compared with the current regulations on Corporate Income Tax (CIT), Decree No. 320/2025/ND-CP introduces many notable new guidance contents, typically as follows:
(i) Corporate Income Tax rates:
- The standard Corporate Income Tax rate is 20%, except for special cases and cases eligible for the tax rates below;
- A 15% tax rate applies to enterprises whose total revenue of the immediately preceding year does not exceed VND 3 billion
- A 17% tax rate applies to enterprises whose total revenue of the immediately preceding year exceeds VND 3 billion but does not exceed VND 50 billion.
Total revenue used as the basis for determining eligibility for the above-mentioned 15% and 17% tax rates includes: total revenue from sales of goods and provision of services (excluding revenue deductions), revenue from financial activities, and other income according to the enterprise’s Statement of Business Results.
(ii) Deductible expenses in determining taxable income for Corporate Income Tax:
- Expenses for the purchase of goods, services, and other payments of VND 5 million or more per transaction must be supported by non-cash payment documents;
- Expenses are recognized as deductible expenses for costs of destruction of raw materials, supplies, and components that are no longer needed for use; costs of destruction of assets that are no longer needed for use; costs of destruction of scrap and defective products arising during the production process. Destruction costs include the remaining value recorded in the enterprise’s accounting books and costs related to the destruction activities;
- Expenses are recognized as deductible expenses for market research costs; research costs for products and services serving the development of new products and services; investment costs for projects developing new products and services that are unsuccessful or must be discontinued; costs incurred by bidders participating in bidding activities but failing to win the bid;
- Deductible expenses are recognized for output VAT on goods given as gifts to customers free of charge, etc.
Decree No. 320/2025/ND-CP takes effect from December 15, 2025 and is applicable to the Corporate Income Tax finalization period for the 2025 tax year.
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