Luật thuế thu nhập doanh nghiệp năm 2025 số 67/2025/QH15 – Toàn văn

 

LAW

CORPORATE INCOME TAX

Pursuant to Constitution of the Socialist Republic of Vietnam;

The National Assembly hereby promulgates the Law on Corporate Income Tax.

Chapter I

GENERAL PROVISIONS

Article 1. Governing scope

This Law provides for taxpayers, taxable income, income excluded from taxable income (hereinafter referred to as “tax-exempt income”), tax bases, tax calculation methods and tax incentives.

Article 2. Taxpayers

1. Taxpayers are organizations earning taxable income from production of goods, sale of goods and services as prescribed by this Law (hereinafter referred to as "enterprises"), including:

a) Enterprises established under Vietnamese law;

b) Enterprises established under foreign laws (hereinafter referred to as "foreign enterprises") with or without Vietnam-based permanent establishments;

c) Cooperatives, cooperative unions established in compliance with provisions of the Law on Cooperatives;

d) Public service providers established under Vietnamese law;

dd) Other organizations earning income from production and business operations (hereinafter referred to as “business operations”).

2. Enterprises having taxable incomes under Article 3 of this Law shall pay corporate income tax as follows:

a) Enterprises established under Vietnamese laws shall pay tax on taxable incomes generated in and outside Vietnam;

b) Foreign enterprises with Vietnam-based permanent establishments shall pay tax on taxable incomes generated in Vietnam and taxable incomes generated outside Vietnam which are related to the operation of such establishments;

c) Foreign enterprises with Vietnam-based permanent establishments shall pay tax on taxable incomes generated in Vietnam which are not related to the operation of such permanent establishments;

d) Foreign enterprises without Vietnam-based permanent establishments, including those engaged in e-commerce and digital platform-based businesses, shall pay tax on taxable incomes generated in Vietnam.

3. The permanent establishments of a foreign enterprise are production and business facilities through which the foreign enterprise carries out part or the whole business operations in Vietnam, including:

a) Branches, executive offices, factories, workshops, means of transport, oil fields, gas files, miles or other natural resource extraction sites in Vietnam;

b) Construction sites;

c) Service providing centers, including counseling services via employees or other organizations or individuals;

d) Agents of foreign enterprises;

dd) Vietnam-based representatives, in case of representatives that are competent to conclude contracts in the name of foreign enterprises or representatives that are incompetent to conclude contracts in the name of foreign enterprises but regularly deliver goods or provide services in Vietnam;

e) E-commerce platforms and digital platforms through which foreign enterprises provide goods and services in Vietnam.

4. The Government of Vietnam shall elaborate this Article.

Article 3. Taxable incomes

1. Taxable incomes include income from goods and service business operations and other incomes specified in Clause 2 of this Article.

2. Other incomes include:

a) Income from transfer of capital, transfer of the right to capital contribution, transfer of securities;

b) Income from real estate transfer, except for income from transfer of real estate of real estate businesses;

c) Income for transfer of investment projects, transfer of the right to participate in investment projects, transfer of the right to mineral exploration, mineral extraction, and mineral processing;

d) Income from transfer, lease and liquidation of assets including valuable papers, except for real estate;

dd) Income from the property use right and property ownership, including income from intellectual property rights and technology transfer

e) Income from deposit interest, loan interest, sale of foreign exchange, except for income from credit operations of credit institutions;

g) Accrued expenses which are not fully settled or only partially settled but are not recorded as a decrease in deductible expenses; collected bad debts that were cancelled; debts payable without identifiable creditors; discovered income from business operation in previous years that were omitted;

h) The discrepancy between the collected penalties, compensation for breaches of economic contracts or bonuses for fulfilling commitments under the contracts;

i) Financial or in-kind donations and grants received;

k) Differences arising from the revaluation of assets according to laws for capital contribution, transfer during mergers, consolidations, full divisions, partial divisions, ownership changes, and conversion of business types;

l) Income from business cooperation contracts;

m) Income from business operations abroad;

n) Income of public service providers for activities related to the leasing of public property;

o) Other income, excluding the tax-exempt income prescribed in Article 4 of this Law.

3. Taxable income generated in Vietnam of foreign enterprises stipulated in points c and d of Clause 2 Article 2 of this Law is income received that originates from Vietnam, regardless of the location of business operation.

4. Vietnamese enterprises investing abroad that generate income from business operations overseas during the tax period may deduct the corporate income tax payable according to the regulations of the host country from the corporate income tax payable in Vietnam, but this deduction must not exceed the corporate income tax calculated according to the provisions of Vietnamese corporate income tax law.

5. Enterprises must pay an additional corporate income tax based on the Income Inclusion Rule (IIR) as stipulated by law; thus, the additional corporate income tax payable can be deducted from the corporate income tax payable in Vietnam as per the provisions of this Law.

6. The Government of Vietnam shall elaborate this Article.

Article 4. Tax-exempt incomes

1. Income from marine fisheries; income from the production of products from crops, planted forests, breeding, cultivation and processing of agriculture and aquaculture products (including purchase of agriculture and aquaculture products for processing) in disadvantaged areas or extremely disadvantaged areas; income of cooperatives, cooperative unions from the production of products from crops, planted forests, breeding, cultivation and processing of agriculture and aquaculture products (including purchase of agriculture and aquaculture products for processing), salt production.

2. Income of cooperatives, cooperative unions engaged in agriculture, forestry, fishery, or salt production in disadvantaged areas or extremely disadvantaged areas.

3. Income from the application of technical services directly for agriculture.

4. Income from the performance of contracts on scientific research and technological development and innovation, and digital transformation; income from the sale of products turned out with technologies applied for the first time in Vietnam; income from the sale of trial products during the period of trial production including trial production conducted under controlled conditions in accordance with legal regulations. Income stated in this clause shall be exempt from tax for a maximum period of three years.

5. Incomes from goods and service business operations of enterprises at least 30% of the annual average number of employees of which are disabled people, detoxified people, HIV/AIDS patients, and have an annual average number of employees of at least 20, except for enterprises engaged in finance and real estate business.

6. Income from vocational education and training activities exclusively reserved for ethnic minority people, the disabled, children in extremely disadvantaged circumstances and persons involved in social evils.

7. Income distributed from capital contributions, share purchases, joint ventures or associations with domestic enterprises, after corporate income tax has been paid under the provisions of this Law, including cases where the capital contribution recipients, stock issuers, joint ventures or associations are eligible for corporate income tax incentives.

8. Grants received for use in educational, cultural, artistic, charitable, humanitarian and other social activities in Vietnam; grants received from enterprises that are not related parties, organizations and individuals both domestically and internationally for the purpose of scientific research, technology development, innovation, and digital transformation; direct support from the state budget and from the Investment Support Fund established by the Government; compensation from the State as prescribed by law.

In cases where the received grants stated in this clause are misused by the enterprises, tax recapture and penalties for violations shall be imposed in accordance with provisions of law.

9. The difference arising from the revaluation of assets in accordance with provisions of law for the purposes of equitization and restructuring of enterprises of which 100% charter capital is possessed by the State.

10. Income from the transfer of Certified Emissions Reductions (CERs), the initial transfer of carbon credits after issuance by enterprises granted Certified Emissions Reductions (CERs) and carbon credits; income from interest on green bonds; income from the initial transfer of green bonds after issuance.

11. Income (including interest from bank deposits, interest from government bonds, and interest from treasury bills) from performing the tasks assigned by the State in the following circumstances:

a) Income of the Vietnam Development Bank from development investment credit and export credit activities;

b) Income of the Vietnam Bank for Social Policies from credit operations for the poor and other beneficiaries;

c) Income of the single-member limited liability companies managing assets of credit institutions in Vietnam;

d) Income from revenue-generating activities of state financial funds and other state organizations operating on a non-profit basis as prescribed or decided by the Government or the Prime Minister.

12. The undistributed income of private facilities that invest in the education – training, healthcare, and other sectors in which private investment is encouraged that is retained to invest in those facilities’ development, in accordance with the minimum ratio prescribed by the Government; income contributed to the creation of an undistributed common fund or undistributed common assets of cooperatives and cooperative unions that are established and operating established and operating in accordance with the regulations of the law on cooperatives.

13. Incomes from transfer of technologies that are prioritized to be to organizations and individuals in extremely disadvantaged areas.

14. Income of public service providers from the provision of public services, including:

a) Basic and essential public services included in the list of public services using state budget issued by the competent authority;

b) Public services requiring the State’s subsidization or funding due to the undercalculation of service provision costs in the service charges;

c) Public services in extremely disadvantaged areas.

15. The Government of Vietnam shall elaborate this Article.

Article 5. Tax period

1. A corporate income tax period may be a calendar year or a fiscal year as decided by enterprises, except the cases defined in Clause 2 of this Article. In case an enterprise chooses a fiscal year that is not the calendar year, a notification must be submitted to the supervisory tax authority before implementation.

2. The tax period for the enterprises specified in point c, point d clause 2 Article 2 of this Law shall comply with the provisions of law on tax administration.

Chapter II

TAX BASES AND TAX CALCULATION METHODS

Article 6. Tax bases

Tax bases include assessable income and tax rate.

Article 7. Determination of assessable income

1. Assessable income in a tax period is determined as follows:

2. Taxable income specified in clause 1 of this Article is determined as follows:

3. An enterprise engaged in multiple business operations during the tax period shall have their taxable income from business operations calculated as the total income from all such operations. In cases of losses incurred in the business operations, these losses may be offset against the taxable income of other business operations generating income, as chosen by the enterprise (excluding income from real estate transfers, investment project transfers, and transfers of rights to participate in investment projects that cannot be offset against the income from business operations currently enjoying tax incentives). The remaining income after offsetting is subject to the corporate income tax rate applicable to business operations.

4. Taxable income from transfers of investment projects to explore, extract and process minerals; transfers of right to participate in investment projects to explore, extract, and process minerals; transfers of right to explore, extract and process minerals must be separately identified for tax declaration and payment, and cannot be offset against losses or profits from business operations during the tax period.

Article 8. Revenues

1. Revenue for calculating taxable income is the total sales, processing remuneration, service provision charges, including subsidies and surcharges enjoyed by enterprises, regardless of whether the payment has been received or not.

2. The Government of Vietnam shall elaborate this Article.

Article 9. Deductible and non-deductible expenses upon determination of taxable incomes

1. Except for the expenditures mentioned in Clause 2 of this Article, all expenditures of an enterprise may be deductible when calculating taxable income if they meet the conditions below:

a) Actual expenditures on business operation of the enterprise, including additional deductible expenses that are a percentage (%) of the actual expenses incurred during the tax period related to the enterprise's research and development activities;

b) Other actual expenditures incurred, including:

b1) Expenditures on national defense and security education, training, activities of the self-defense forces, and other national defense and security tasks as prescribed by law;

b2) Expenditures on activities of party organizations and political-social organizations within the enterprise;

b3) Expenditures on vocational education and training for workers in accordance with the provisions of the law;

b4) Actual expenditures on HIV/AIDS prevention and control in the workplace of the enterprise;

b5) Funding for education, healthcare, culture; funding for disaster prevention, mitigation of disaster and epidemic consequences, funding for building solidarity houses, houses of affection, and homes for policy beneficiaries as prescribed by law; funding as regulated by the Government and the Prime Minister for extremely disadvantaged areas; funding for scientific research, technological development and innovation, and digital transformation;

b6) Expenditures on scientific research, technological development and innovation, and digital transformation;

b7) Value of losses due to natural disasters, diseases, and other cases of force majeure where compensation is not eligible for;;

b8) Actual expenses for individuals seconded to participate in the management, operation and control of credit institutions put under special control and commercial banks undergo mandatory transfer in accordance with the Law on Credit Institutions;

b9) Certain operating expenses of the enterprise that do not correspond with the revenue generated during the period as stipulated by the Government.

b10) Expenditures on supporting the construction of public works, while also serving the business operation of the enterprise.

b11) Expenditures related to the reduction of greenhouse gas emissions aimed at carbon neutrality and net zero, reducing environmental pollution as well as the production and business of the enterprise;

b12) Some contributions to funds established under the decision of the Prime Minister and regulations of the Government;

c) Expenditures with adequate invoices and proofs of cashless payment in accordance with provisions of law, except for specific cases stipulated by the Government.

2. Non-deductible expenses upon determination of taxable incomes include:

a) Expenditures not fully satisfying the requirements specified in Clause 1 of this Article;

b) Fine for administrative violations;

c) Expense already covered by other funding sources;

d) Expense in excess of the Government-prescribed norm for: Business management costs allocated by foreign enterprises to their Vietnam-based permanent establishments; costs of management of gambling video game businesses and casinos; payment of interests on loans taken by enterprises with related-party transactions; direct payment of benefits for employees; contributions to additional pension insurance as mandated by the Social Insurance Law or social welfare-like funds, voluntary pension insurance, and life insurance for employees;

dd) Provisions made incorrectly or exceeding the limits set by the law regarding provisions;

e) Depreciation expense for fixed assets that is incorrect or exceeds the limits prescribed by law;

g) Improper prepaid expenses;

h) Wages and remunerations of owners of sole proprietorships, individual owners of single-member limited liability companies; wages of founders that do not directly participate in production and business management; wages, remunerations, and accounting expenses allocated for the employees that are not actually paid or are paid without invoices or payment documents as prescribed by law;

i) Payment of interests on loans corresponding to the charter capital deficit; interest payments for loans during the investment process that have been recorded in the investment value; interest payments for loans for the implementation of contracts for oil and gas exploration and exploitation; payment of interests on business loans of entities that are not credit institutions that exceed the limits prescribed by the Civil Code;

k) Recoverable expenses exceeding the rate stipulated in the approved petroleum contract; in cases where the petroleum contract does not specify a recovery rate, the expenses exceeding the limits set by the Government shall not be considered deductible expenses.

l) The input value-added tax (VAT) that has been deducted; the VAT paid using the credit-invoice method; the input VAT on the value of passenger cars with fewer than 10 seats exceeding the limits set by the Government; corporate income tax; other taxes, fees, charges, and revenues not considered as expenses according to the provisions of law, and late payment interests as stipulated by the law on tax administration.

The VAT paid using the credit-invoice method specified in this point shall not include the input VAT on goods and services directly related to the production and business of the enterprise that has not been fully deducted and also not refundable.

The input VAT that has been recorded as deductible expenses shall not be deducted from the output VAT.

m) Expenses not corresponding to assessable revenue, except for the expenses specified in point b, clause 1 of this Article; expenses that do not meet the conditions for expenditure and the items of expenditure as stipulated by specialized laws;

n) Donations, except for donations specified in point b5 clause 1 of this Article;

o) Expenditures on basic construction investment during the investment period to form fixed assets; expenditures directly related to the increase or decrease of the enterprise's equity.

p) Expenses of business operations: banking, insurance, lottery, securities, BT contracts, BOT contracts, and BTO contracts that are incorrect or exceed the limits prescribed by law;

q) Other expenses.

3. The Government shall elaborate on this Article, including additional expenditure levels, conditions, period and scope for expenditures on research and development of the enterprise specified in point a clause 1 of this Article.

The Ministry of Finance shall specify the documentation for the expenses recorded as deductible expenses specified in points b and c of Clause 1 of this Article.

Article 10. Tax rate

1. The corporate income tax rate shall be 20%, except for the cases in Clauses 2, 3 and 4 of this Article and beneficiaries of tax incentives prescribed in Article 13 of this Article.

2. A tax rate of 15% shall apply to enterprises whose total annual revenue does not exceed 3 billion VND.

3. A tax rate of 17% shall apply to enterprises whose total annual revenue is from over 3 billion VND to 50 billion VND.

The revenue used as the basis for identifying enterprises eligible for the tax rates of 15% and 17% specified in clause 2 and clause 3 of this Article is the total revenue for the preceding corporate income tax period. The determination of total revenue serving as the basis for implementation shall comply with the regulations of the Government.

4. The corporate income tax rate applicable to some of other cases shall be as follows:

a) For oil and gas exploration and exploitation, the tax rate shall be from 25% to 50%. Based on the location, exploitation conditions, and mineral reserves of the mine, the Prime Minister shall decide the specific tax rate applicable to each petroleum contract;

b) For exploration and exploitation of rare resources (including: platinum, gold, silver, tin, tungsten, antimony, gemstones, rare earths, and other rare resources as stipulated by law), the tax rate shall be 50%. In cases where 70% or more of the allocated area belongs to extremely disadvantaged areas, the tax rate shall be 40%.

Article 11. Tax calculation methods

1. Corporate income tax payable in a tax period equals (=) assessable income multiplied by (x) tax rate, except for the case specified in clause 2 of this Article.

2. The Government shall specify the rates of corporate income tax payable on revenue by the following entities:

a) Enterprises specified in points c and d of clause 2, Article 2 of this Law; entities required to declare and pay taxes, the time and method for determining revenue subject to income tax arising in Vietnam;

b) Enterprises whose total annual revenue do not exceed 3 billion VND as stipulated in Clause 2, Article 10 of this Law, in cases where revenue can be determined but costs and incomes from business operations cannot be identified;

c) Cooperatives, cooperative unions, public service providers and other organizations specified in points c, d, and e of clause 1, Article 2 of this Law that engage in the goods and service business operations, generate income subject to corporate income tax (excluding tax-exempt income stipulated in Article 4 of this Law) and have recorded their revenues but are unable to determine the costs and income from their business operations.

Chapter III

CORPORATE INCOME TAX INCENTIVES

Article 12. Principles and regulated entities of corporate income tax incentives

1. Enterprises are entitled to corporate income tax incentives based on the sectors and industries eligible for corporate income tax incentives, as well as the geographical areas eligible for corporate income tax incentives specified in this Article. The corporate income tax incentives shall comply with the provisions of Article 13 and Article 14 of this Law.

In cases where other laws provide for corporate income tax incentives that differ from the provisions of this Law, the provisions of this Law shall be applied, except for the Law on the Capital and resolutions that stipulate special mechanisms and policies of the National Assembly.

At the same time, if an enterprise is entitled to multiple tax incentives under this Law for the same income, the enterprise may choose to apply the most beneficial tax incentive.

2. The sectors and industries eligible for corporate income tax incentives include:

a) Application of high technology, venture capital investing for the development of high technology included in the list of high technology that is prioritized for investment and development in accordance with the Law on High Technology; the application of strategic technology as prescribed by law; high technology incubation, incubation of high-tech enterprises; investment in the construction and operation of high-tech incubators, high-tech enterprise incubators;

b) Production of software products; production of network security products and provision of network security services in accordance with legal regulations on network security; production of key digital technology products, provision of key digital technology services, and manufacturing of electronic devices in accordance with the law on digital technology industry; research and development, design, production, packaging, testing of semiconductor chip products; establishment of artificial intelligence data centers;

c) Production of supporting industry products that are included in the list of supporting industry products given priority for development that are required to meet one of the following criteria as stipulated by the Government:

c1) Supporting industry products for high technology as stipulated by the Law on High Technology;

c2) Supporting industry products for the production of products in the textile - garment, leather - footwear, electronics - information technology (including semiconductor production and design), automobile manufacturing and assembly, and mechanical engineering, as of the effective date of this Law, which have not yet been produced domestically or have been produced domestically but must meet the technical standards of the European Union or equivalent (if any) as prescribed by the Minister of Industry and Trade;

d) Production of renewable energy, clean energy, energy from waste disposal; environmental protection; the production of composite materials, various types of lightweight building materials, and rare materials; production of national defense and security products and industrial mobilization products according to the provisions of law on national defense, security and industrial mobilization; production of key industrial chemicals and key mechanical products in accordance with the law;

dd) Investment in the development of water plants, power plants, water supply and drainage systems, bridges, roads, railways, airports, seaports, river ports, airports, stations, and other particularly important infrastructure works as decided by the Prime Minister;

e) High-tech enterprises and hi-tech agriculture enterprises stipulated by the Law on High Technology; scientific and technological enterprises stipulated by the Law on Science, Technology and Innovation;

g) Investment projects in the manufacturing sector that meet the following requirements:

g1) These projects have a minimum investment capital scale of 12 trillion VND and must complete the disbursement of the total registered investment capital within 05 years from the date of investment approval according to investment laws;

g) These projects must use technology that meets the requirements set forth by the Minister of Science and Technology;

h) These projects must be entitled to special investment support and incentives specified in clause 2 Article 20 of the Law on Investment. The Government shall elaborate on the period of disbursement of the total registered investment capital of these projects;

i) Planting, caring for and protecting forests; producing, reproducing and crossbreeding crops and livestock; investing in the preservation of agricultural products after harvest, storing agricultural products, aquatic products and food; producing, exploiting and refining salt, except for the salt production specified in Clause 1 of Article 4 of this Law;

k) Cultivation of forest products;

l) Products from crops, planted forests, livestock farming, aquaculture and the processing of agricultural products, and aquatic products.

The income from the processing of agricultural and aquatic products stipulated in this point must meet the requirements set forth in clause 1, Article 4 of this Law;

m) Production of high-quality steel; production of energy-saving products; manufacturing of machinery and equipment for agriculture, forestry, fishery and salt production; production of irrigation equipment; production of animal feed for livestock, poultry and aquatic products;

n) Production and assembly of automobiles; production of other digital technology products;

o) Investment in business operations of technical facilities supporting small and medium-sized enterprises and small and medium-sized enterprise incubators; investment in business operations of co-working spaces supporting small and medium-sized startups in accordance with the provisions of the Law on Provision of Assistance for Small and Medium-sized Enterprises.

p) The People’s credit funds, microfinance institutions, cooperative banks;

q) Cooperatives and cooperative unions operating in the fields of agriculture, forestry, fishery, and salt production;

r) Private sector involvement in the fields of education, training, vocational training, healthcare, culture, sports and environment according to the List of types, criteria of scale and standards prescribed by the Prime Minister; judicial assessment;

s) Investment in the construction of social housing for sale, lease or lease-purchase for individuals eligible for social housing support policies as stipulated by the Housing Law;

t) Publication in accordance with the provisions of the Publishing Law;

u) The press (including advertisements in newspapers) as stipulated by the Press Law.

3. Geographical areas entitled to corporate income tax incentives as stipulated by the Government include:

a) Extremely disadvantaged areas;

b) Disadvantaged areas;

c) Economic zones, high-tech zones, high-tech agricultural areas, and concentrated digital technology zones.

4. The government stipulates the application of tax incentives for the following cases:

a) Cases of applying tax incentives based on geographic criteria;

b) Tax incentives in the fields of agriculture, forestry, fishery, and salt production;

c) The cases where an enterprise generates revenue or income from investment projects (including new investment projects, expanded investment projects, high-tech enterprises, high-tech agriculture enterprises, and scientific and technological enterprises) in its first tax period and is entitled to tax incentives for less than 12 months.

5. The newly established enterprise or the enterprise with an investment project resulting from a merger, consolidation, full division, partial division, change of ownership, or change of business form shall be responsible for fulfilling the obligation to pay corporate income tax (including any penalties, if applicable). At the same time, it shall inherit corporate income tax incentives (including the losses that have not been carried forward) of the enterprise or investment project prior to the merger, consolidation, full division, partial division, or change of ownership, provided that it continues to meet the eligibility requirements for corporate income tax incentives and loss carryforward conditions as stipulated by law.

Article 13. Preferential tax rates

1. The tax rate of 10% shall apply for 15 years to:

a) Incomes of enterprises from the execution of new investment projects specified in points a, b, c, d and dd clause 2 Article 12 of this Law; income of enterprises specified in point e clause 2 Article 12 of this Law;

b) Incomes of enterprises from the execution of investment projects specified in points g and h clause 2 Article 12 of this Law;

c) Incomes of enterprises from the execution of new investment projects in the areas specified in point a clause 3 Article 12 of this Law;

d) Incomes of enterprises from the execution of new investment projects in high-tech zones, high-tech agriculture zones, concentrated digital technology zones; new investment projects in economic zones located in areas eligible for tax incentives as stipulated in points a and b of Clause 3 of Article 12 of this Law. In cases where an investment project in an economic zone is located in both an area eligible for tax incentives and an area not eligible for tax incentives, tax incentives for the project shall be determined in accordance with the Government’s regulations.

2. The tax rate of 10% shall apply to:

a) Incomes of enterprises from operations in the sectors and industries specified in points k and l Clause 2, Article 12 of this Law in the areas eligible for tax incentives specified in point b of Clause 3 Article 12 of this Law;

b) Incomes of enterprises from operations in the sectors and industries specified in points i, r and s clause 2 Article 12 of this Law;

c) Incomes of publishers from operations in the sectors and industries specified in point t clause 2 Article 12 of this Law;

d) Incomes of cooperatives and cooperative unions specified in point q clause 2 Article 12 of this Law in areas other than the areas specified in clause 3 Article 12 of this Law;

dd) Incomes of press agencies in the sectors and industries specified in point u clause 2 Article 12 of this Law;

3. The tax rate of 15% shall apply to incomes of enterprises from operations in the sectors and industries specified in point l Clause 2 Article 12 of this Law located in areas other than the areas specified in Clause 3 Article 12 of this Law;

4. The tax rate of 17% shall apply for 10 years to:

a) New investment projects in sectors and industries eligible for incentives stipulated in points m, n, and o of Clause 2, Article 12 of this Law;

b) New investment projects executed in the areas specified in point b clause 3 Article 12 of this Law;

c) New investment projects in economic zones in areas other than the areas specified in points a and b clause 3 Article 12 of this Law.

5. The tax rate of 17% shall apply to incomes of the enterprises specified in point p clause 2 Article 12 of this Law.

6. The extension of the period and the application of preferential tax rate shall be as follows:

a) The Prime Minister decides that the preferential tax period may be extended for up to 15 years for the following projects:

a1) New investment projects stipulated in points a, b, d and dd of Clause 2 Article 12 of this Law, with a minimum investment capital of 6 trillion VND, which have a significant socio-economic impact, in need of great encouragement;

a2) Investment project specified in point g clause 2 of Article 12 of this Law meeting one of the following criteria:

- Goods are produced with global competitive capability. Revenue rises by over 20 trillion VND per year within 5 years from the date on which the investment project generates revenue;

- Over 6,000 employees defined by labor laws are used regularly;

- Investment projects in the field of technical economic infrastructure, including: Investment in the development of water plants, power plants, water supply and drainage systems, bridges, roads, railways, airports, seaports, river ports, airports, terminals, new energy, clean energy, energy-saving industries, and petroleum refining projects;

b) For a new investment project stipulated in point h, clause 2, Article 12 of this Law, the Prime Minister decides the application of a decrease in tax rate of not exceeding 50% of the tax rate specified in clause 1 of this Article; the preferential tax period shall not exceed 1,5 times the preferential tax period specified in clause 1 of this Article and may be extended for up to 15 years but must not exceed the duration of the investment project.

7. The preferential tax period applicable to the income generated from the execution of a new investment project by an enterprise stipulated in this Article (including projects specified in point g, clause 2 of Article 12 of this Law) shall begin from the first year in which the new investment project of the enterprise generates revenue.

In cases where the enterprise is granted a Certificate of high-tech enterprise, a Certificate of high-tech agriculture enterprise, a Certificate of scientific and technological enterprise, a Certificate of a high-tech application project, or a Confirmation of incentives for supporting industry product manufacturing projects after the time of revenue generation, the preferential tax period shall begin from the year of issuance of the Certificate or Confirmation of incentives.

Article 14. Tax exemption and tax reduction

1. It is eligible for tax exemption for up to 4 years and 50% tax reduction for up to 9 more years for:

a) Incomes of enterprises specified in clause 1 Article 13 of this Law;

b) Incomes of enterprises specified in point r clause 2 Article 12 of this Law in the areas specified in points a and b clause 3 Article 12 of this Law; in cases where enterprise are not located in the areas specified in point a and point b clause 3 Article 12 of this Law, they are eligible for tax exemption for up to 4 years and 50% tax reduction for up to 5 more years.

2. It is eligible for tax exemption for up to 2 years and 50% tax reduction for up to 4 more years for incomes of enterprises specified in clause 4 Article 13 of this Law.

3. With respect to the new investment projects specified in point h clause 2 Article 12 of this Law, the Prime Minister shall decide the extension of the tax exemption or reduction period for up to 1,5 times the tax exemption or reduction period specified in point 1 of this Article.

4. The tax exemption or reduction period shall begin from the first year in which taxable income is generated from the investment project. In cases where the project does not generate any taxable income during the three years starting from the first year in which the project generates revenue, the tax exemption or reduction period shall begin from the fourth year.

In cases where the enterprise is granted a Certificate of a high-tech application project, a Certificate of high-tech enterprise, a Certificate of high-tech agriculture enterprise, a Certificate of scientific and technological enterprise, or a Confirmation of incentives for supporting industry product manufacturing projects after the time of income generation, the tax exemption or reduction period shall begin from the year of issuance of the Certificate or Confirmation. In cases where income has not yet been generated from the project in the year of issuance of the Certificate or Confirmation, the tax exemption or reduction period shall begin from the first year in which the income is generated. If, within the first three years from the issuance of the Certificate or the Confirmation, the enterprise does not have taxable income, the tax exemption or reduction period shall begin from the fourth year following the issuance of the Certificate or the Confirmation.

5. Tax incentives for expansion investment projects:

a) In cases where enterprise expands the scale, enhances capacity, modernizes technology, reduces pollution or improves the environment of its ongoing investment projects within the sectors, industries and areas entitled to corporate income tax incentives stipulated in Article 12 of this Law (hereinafter referred to as "expansion investments”), its additional income generated from investment in the expansion of these projects will be eligible for tax incentives for the remaining period and is not be required to separately record;

b) In cases where the preferential tax period of the ongoing project has expired, the additional income generated from the expansion investment project that meets the criteria specified in Clause 6 of this Article shall be eligible for tax exemption, tax reduction, but shall not be eligible for preferential tax rates. The tax exemption or reduction period for additional income generated from expansion investments shall be equal to the tax exemption or reduction period applicable to new investment projects within the same sector, profession and area eligible for corporate income tax incentives, and shall begin from the year in which the investment project completes the registered investment capital.

The enterprise must separately record the additional income generated from expansion investments in order to apply for incentives. In cases where the addition income cannot be separately recorded, it shall be determined based on the ratio of the original cost of newly acquired fixed assets put into use for business operation to the total original cost of fixed assets of the enterprise.

c) The tax incentives stipulated in this clause do not apply to cases of expansion investments resulting from mergers, acquisitions of enterprises, or ongoing investment projects.

6. An expansion investment project shall be eligible for the incentives specified in point b clause 5 of this Article, provided that it meets one of the following criteria:

a) The additional original cost of fixed assets reaches the minimum cost prescribed by the Government upon completion of the disbursement of the registered expansion investment capital for expansion investment projects in sectors and industries eligible for corporate income tax incentives, and expansion investment projects executed in areas eligible for corporate income tax incentives;

b) The proportion of original cost of fixed assets when the investment project completes the disbursement of the registered expansion investment capital reaches at least 20% of the total original cost of fixed assets before expansion investment;

c) The designed capacity when the investment project completes the disbursement of the registered expansion investment capital increases by at least 20% after expansion investment.

Article 15. Other cases of tax exemption and reduction

1. Enterprises engaged in manufacturing, construction, and transportation that employ a significant number of female workers shall be granted a reduction in corporate income tax equivalent to the additional expenses incurred for female workers.

2. Enterprises employing a significant number of ethnic minority workers shall be granted a reduction in corporate income tax equivalent to the additional expenses incurred for ethnic minority workers.

3. Enterprises transferring technologies in prioritized fields to organizations and individuals in disadvantaged areas and public service providers in disadvantaged areas shall be entitled to a 50% reduction in corporate income tax calculated on the income derived from technology transfer and income from providing public services in disadvantaged areas.

4. Enterprises specified in clause 2 and clause 3 Article 10 of this Law that are newly established from household businesses shall be exempt from corporate income tax for two consecutive years from the date of generating taxable income.

5. Public scientific and technological organizations and public higher education institutions operating not for profit shall be exempt from tax in accordance with the Government’s regulations.

6. The Government of Vietnam shall elaborate this Article.

Article 16. Loss carryforward

1. An enterprise may carry forward its loss to the next year; this loss may be deducted from taxable income. A loss must not be carried forward for more than 5 consecutive years from the year succeeding the year in which the loss is incurred.

2. Enterprises whose losses incurred from transfers of projects to explore, extract and process minerals; transfers of right to participate in projects to explore, extract and process minerals; transfers of right to explore, extract and process minerals may be carry forward the losses to the next year and offset them against the taxable incomes from such transfers. The period of loss carryforward shall comply with clause 1 of this Article.

3. The Government of Vietnam shall elaborate this Article.

Article 17. Contributions to scientific and technological development funds

1. An enterprise, organization or public service provider established in accordance with Vietnamese law may contribute up to 20% of its assessable annual income to a scientific and technological development fund.

2. Within five years after being allocated in accordance with the provisions of clause 1 of this Article, if the enterprise, organization or public service provider does not use the scientific and technological development fund, or has used less than 70% of the fund or has used it for unintended purposes, it shall transfer to state budget the corporate income tax calculated on the income already contributed to the fund but is not used or is improperly used plus (+) interest on that corporate income tax.

The corporate income tax rate used for calculating tax arrears is the tax rate applicable to the enterprise, organization or public service provider during the time of operating the fund.

The interest rate for calculating the interest on the tax arrears on the unused fund shall be the interest rate for five-year term treasury bonds or ten-year term treasury bonds (in the absence of five-year term treasury bonds) issued closest to the collection date, and the interest payment period is two years.

The interest rate for calculating interest on the tax arrears on the fund improperly used shall be the late payment interest rate under the provisions of the Tax Administration Law, and the interest payment period begins from the time the fund is set up and ends when tax arrears are collected.

3. Enterprises, organizations and public service providers are not allowed to record expenses from their scientific and technological development funds as deductible expenses upon the determination of taxable incomes in a tax period.

4. Scientific and technological development funds shall be used in accordance with the provisions of law on science, technology and innovation.

5. For an enterprise currently in operation that undergoes changes due to mergers, consolidations, full divisions, partial divisions, changes of ownership or changes in business type, the newly established enterprise or the enterprise established after merger, consolidation, full division, partial division, change of ownership or change in business type may inherit and shall be responsible for the management and use of the scientific and technological development fund of the enterprise prior to the merger, consolidation, full division, partial division, change of ownership or change in business type.

Article 18. Conditions for tax incentives

1. Corporate income tax incentives specified in Articles 13, 14 and 15 of this Law shall apply only to enterprises which implement regulations on accounting, invoices and documents and pay tax according to declarations.

Corporate income tax incentives for new investment projects (including investment projects falling under point g, clause 2, Article 12 of this Law) as stipulated in Articles 13 and 14 of this Law do not apply to cases of mergers, consolidations, full divisions, partial divisions, changes of ownership, changes of business type, and other cases as regulated by the Government.

2. Each enterprise must separate incomes from the business operations eligible for tax incentives prescribed in Articles 4, 13, 14 and 15 of this Law from incomes from the business operations that are not eligible for tax incentives; if these incomes cannot be separated, the incomes from the business operations eligible for tax incentives shall be determined according to the ratio of the revenue from or expenses for the business operations eligible for tax incentives to the total revenue or total expense of the enterprise.

3. The tax rates of 15% and 17% specified in clause 2 and clause 3 Article 10 of this Law and the tax incentives in Articles 4, 13, 14 and 15 of this Law do not apply to:

a) Incomes from transfers of capital, transfers of the right to contribute capital; incomes from transfers of real estate, except for incomes from investment in construction of social housing specified in point s clause 2 Article 12 of this Law; incomes from transfers of investment projects (except for transfers of projects to process minerals), transfers of the right to participate in investment projects, transfers of the right to explore, extract and process minerals; incomes from business operations outside Vietnam;

b) Incomes from the exploration and extraction of petroleum and other rare resources, and incomes from mineral extraction and extraction;

c) Incomes from the production and operation of online video games; incomes from the production and sale of goods and services subject to excise taxes as stipulated by the Excise Tax Law, except for projects related to the production and assembly of automobiles, aircraft, helicopters, gliders, yachts, and petrochemical refining;

d) Specific cases as regulated by the Government.

4. The tax rates of 15% and 17% specified in clauses 2 and 3 of Article 10 of this Law do not apply to enterprises that are subsidiaries or affiliated companies if the enterprises in the affiliation do not meet the conditions for applying the tax rates stipulated in clauses 2 and 3 of Article 10 of this Law.

5. In cases where enterprises do not meet the conditions for tax incentives, the competent authorities shall collect the tax arrears and impose penalties for violations according to the provisions of law.

6. The Government of Vietnam shall elaborate clause 5 of this Article. The Ministry of Finance shall stipulate the procedures and application for tax incentives set forth in Articles 4, 13, 14, and 15 of this Law.

Chapter IV

IMPLEMENTATION PROVISIONS

Article 19. Entry into force

1. This law comes into force from October 1, 2025 and shall apply from the corporate income tax period of 2025.

2. Law on Corporate Income Tax No. 14/2008/QH12 amended by Law No. 32/2013/QH13, Law No. 71/2014/QH13, Law No. 61/2020/QH14, Law No. 12/2022/QH15, and Law No. 15/2023/QH15 shall cease to be effective from the effective date of this Law.

3. In case Organization for Economic Cooperation and Development (OECD) of the United Nations has more favorable provisions and guidelines for taxing rights of source countries, including Vietnam, the Government shall provide specific regulations for implementation.

 Article 20. Transitional provisions

1. For enterprises with investment projects that are eligible for corporate income tax incentives in accordance with the provisions of law on corporate income tax at the time of licensing or issuance of Investment Certificates, or grant of investment permission in accordance with the provisions of law on investment, in the event that the law on corporate income tax is amended and the enterprises meet conditions for tax incentives in accordance with the amended law, the enterprises may choose to enjoy tax incentives based on the applicable tax rates and tax exemption or reduction periods according to the regulations in effect at the time of licensing or issuance of Investment Certificates, or grant of investment permission, or according to the provisions of the amended law for the remaining tax incentive period.

2. In the case where an enterprise has an investment project that is not eligible for incentives under the provisions of legislative documents on corporate income tax prior to the effective date of this Law but is eligible for incentives under the provisions of this Law, the incentives as stipulated in this Law shall be applied for the remaining period starting from the tax period of 2025.

This Law was passed on June 14, 2025, by the XVth National Assembly of the Socialist Republic of Vietnam at its 9^th session.