Law on Personal Income Tax No. 109/2025/QH15

LAW

INCOME TAX

Pursuant to the Constitution of the Socialist Republic of Vietnam amended and supplemented by Resolution No. 203/2025/QH15;

The National Assembly enacts the Personal Income Tax Law.

PART I

GENERAL PROVISIONS

Article 1. Scope of Regulation

This Law regulates taxpayers, taxable income, tax-exempt income, reduced tax income, and the basis for calculating personal income tax.

Article 2. Taxpayers

1. A taxpayer of personal income tax is an individual residing in Vietnam who has taxable income as defined in Article 3 of this Law arising within and outside the territory of Vietnam, and a non-resident individual who has taxable income as defined in Article 3 of this Law arising within the territory of Vietnam.

2. A resident individual is one who meets one of the following conditions:

a) Being present in Vietnam for 183 days or more within one calendar year or over a continuous period of 12 months starting from the first day of presence in Vietnam;

b) Having a permanent place of residence in Vietnam, including having a registered place of permanent residence or renting a house to reside in Vietnam under a lease agreement with a fixed term.

3. A non-resident individual is one who does not meet the conditions specified in Clause 2 of this Article.

4. The Government shall provide detailed regulations on this matter.

Article 3. Taxable Income

Personal income tax includes the following types of income, except for tax-exempt income as stipulated in Article 4 of this Law:

1. Income from business activities, including:

a) Income from production and business operations of goods and services;

b) Income from independent professional activities of individuals holding a license or certificate according to the law;

c) Income from agency, brokerage, and joint business ventures with organizations;

d) Income from e-commerce and business based on digital platforms.

2. Income from wages and salaries, including:

a) Wages, salaries, and other amounts with the nature of wages and salaries;

b) Honoraria, benefits in cash or kind in any form;

c) Allowances, subsidies, and other income excluding allowances and subsidies provided for in the law on preferential treatment for persons with meritorious service; defense and security allowances; allowances for hazardous and dangerous work environments; attraction allowances; regional allowances as prescribed by law; living expenses paid by Vietnamese agencies abroad; emergency hardship assistance, work injury compensation, occupational disease compensation, one-time maternity allowance or adoption allowance, disability pension, monthly survivor's pension, and other allowances as prescribed by the social insurance law; severance pay, unemployment benefits; social welfare allowances, and other allowances and income that do not have the nature of wages and salaries as prescribed by the Government.

3. Income from capital investment, including:

a) Interest from loans;

b) Dividend income;

c) Income from other forms of capital investment.

4. Income from transfer of capital, including:

a) Income from transferring shares in economic organizations;

b) Income from transferring securities;

c) Income from other forms of capital transfer.

5. Income from transfer of real estate, including:

a) Income from transferring land use rights and attached assets;

b) Income from transferring ownership or usage rights of housing;

c) Income from transferring land rental rights, water surface rental rights;

d) Other income received from transferring real estate in any form.

6. Income from lottery winnings, including:

a) Lottery winnings;

b) Winnings from promotional activities;

c) Winnings from betting activities;

d) Winnings from games, contests with prizes, and other forms of winnings, excluding casino winnings.

7. Income from copyright, including:

a) Income from transferring or licensing the use of intellectual property objects;

b) Income from technology transfer.

8. Income from franchising.

9. Income from inheritance or gifts of securities, shares in economic organizations, businesses, real estate, and other assets requiring registration of ownership or usage rights.

10. Other income, including:

a) Income from transferring national Vietnamese internet domain names ".vn";

b) Income from transferring greenhouse gas emission reduction results, carbon credits;

c) Income from transferring vehicle license plates won through auctions as prescribed by law;

d) Income from transferring digital assets;

đ) Income from transferring gold bars.

The Government shall specify the threshold value of gold bars subject to taxation, the timing of applying and adjusting the personal income tax rate for the transfer of gold bars in accordance with the management plan for the gold market.

11. The Government shall provide detailed regulations on this matter and the conversion of income received in non-cash or non-Vietnamese Dong forms.

Article 4. Tax-exempt Income

1. Income from the transfer, inheritance, or gift of real estate between spouses; biological parents and children; adoptive parents and adopted children; father-in-law, mother-in-law and daughter-in-law; father-in-law, mother-in-law and son-in-law; paternal grandfather, paternal grandmother and grandson; maternal grandfather, maternal grandmother and granddaughter; siblings.

2. Income from the transfer of housing, land use rights, and attached assets of individuals when the individual only has one single house and land plot in Vietnam.

3. Value of land use rights granted to individuals by the State.

4. Income of households and individuals directly producing agricultural products, planted forests, livestock breeding, aquaculture, and fishing without further processing or only simple processing; salt production; income from dividend income of members of agricultural cooperatives, agricultural cooperative unions, farmers signing contracts with enterprises participating in "Large Fields", planted forests, aquaculture.

5. Income from converting agricultural land of households and individuals assigned by the State for production purposes.

6. Income from government bond interest, local government bond interest, interest from deposits at credit institutions, and life insurance contract interest.

7. Income from remittances.

8. Wages for night work, overtime work, wages, and fees paid for days off as prescribed by law.

9. Retirement pay from the Social Insurance Fund; income from supplementary pension funds and voluntary pension funds.

10. Income from scholarships, including:

a) Scholarships received from the state budget;

b) Scholarships received from domestic and foreign organizations under their scholarship support programs.

11. Income from insurance contract settlements, both life and non-life insurance, accident compensation at work, state compensation, and other compensations as prescribed by law.

12. Income received from charitable organizations and funds established or recognized by competent state authorities for charitable and humanitarian purposes without profit motives.

13. Income received from foreign aid for charitable and humanitarian purposes in the form of government and non-governmental organizations approved by competent state authorities.

14. Income from wages and fees of Vietnamese seafarers working for foreign shipping companies or Vietnamese international shipping companies.

15. Income of individuals who are ship owners, individuals with the right to use ships, and individuals working on ships from activities providing goods and services directly serving offshore fishing operations.

16. Income from the first transfer of greenhouse gas emission reduction results recognized for individuals, carbon credits for individuals granted carbon credits; income from green bond interest; income from the first transfer of green bonds after issuance.

17. Income from wages and fees from performing scientific and technological tasks and innovation.

18. Income from copyright of scientific and technological tasks and innovation when the results of the tasks are commercialized according to laws on science, technology, and innovation, and intellectual property laws.

19. Income of individual investors, experts from creative startup projects, founders of creative startups, and individual investors contributing capital to venture investment funds.

20. Income from wages and fees of foreign experts working in programs and projects funded by non-repayable ODA, foreign non-governmental organization programs in Vietnam; individuals who are Vietnamese working at representative offices of international organizations belonging to the United Nations system in Vietnam; individuals participating in United Nations peacekeeping forces.

21. Income after corporate income tax has been paid by individual owners of private enterprises, individual owners of limited liability companies with one member.

22. The Government shall provide detailed regulations for this Article.

Article 5. Other cases of tax exemption and tax reduction

1. Taxpayers encountering difficulties due to natural disasters, epidemics, fires, accidents, serious illnesses affecting their ability to pay taxes may be granted tax reductions corresponding to the extent of damage but not exceeding the amount of tax payable.

2. Exemption from personal income tax for a period of five years on income from wages and fees of high-quality digital industry human resources in the following cases:

a) Income from digital industry projects operating in concentrated digital technology zones;

b) Income from research and development projects, production of key digital products, semiconductor chips, artificial intelligence systems;

c) Income from training activities for digital industry human resources.

3. Exemption from personal income tax for a period of five years on income from wages and fees of high-tech personnel implementing high-tech or strategic technology research and development activities included in the list of priority high-tech investments or the list of strategic technologies and strategic technology products as prescribed by high-tech laws.

4. Exemption from personal income tax on the transfer of open-ended fund certificates established in accordance with securities laws held for two years or more from the date of purchase.

5. Reduction of fifty percent of personal income tax on the income of individual investors distributed from securities investment funds and real estate investment funds established in accordance with the Securities Law within the time limit prescribed by the Government.

6. The Government shall provide detailed regulations for this Article.

Article 6. Tax administration for personal income tax

Based on the provisions of this Law, the Government shall specify the tax year for calculating tax on business income and income from wages and fees of resident individuals, and the calculation period for each occurrence of other income of resident and non-resident individuals; the time point for determining taxable income; settlement of tax; refund of tax for cases where the individual's tax payment exceeds the tax payable or does not reach the threshold for tax payment; withholding, reporting, and paying on behalf of taxpayers in accordance with the Tax Administration Law.

Chapter II

BASIS FOR CALCULATING TAX FOR RESIDENT INDIVIDUALS

Article 7. Personal income tax on business income

1. Resident individuals engaged in production and business activities with annual revenue up to 500 million VND are exempt from personal income tax. The Government shall submit to the Standing Committee of the National Assembly for adjustment of the revenue threshold exempt from personal income tax to suit economic and social conditions in each period.

2. Personal income tax on business income of resident individuals with annual revenue above the threshold specified in Clause 1 of this Article is determined by multiplying the taxable income by the tax rate. In which: a) Taxable income is determined by subtracting related production and business expenses during the tax calculation period from the revenue of goods and services sold;

b) Individuals with annual revenue above the threshold specified in Clause 1 of this Article up to 3 billion VND: tax rate 15%;

c) Individuals with annual revenue above 3 billion VND up to 50 billion VND: tax rate 17%;

d) Individuals with annual revenue above 50 billion VND: tax rate 20%.

d) Individuals engaged in business with annual revenue over 50 billion VND: tax rate of 20%.

Income from leasing real estate as specified in Clause 4 of this Article shall not apply the tax calculation method prescribed in this Clause.

3. Individuals engaged in business with annual revenue between the level prescribed in Clause 1 of this Article and up to three billion dong may choose to pay taxes according to the provisions at Point a and Point b of Clause 2 of this Article or pay taxes at a rate multiplied (x) by taxable revenue. Taxable revenue and tax rates are determined as follows:

a) Taxable revenue is determined by the portion of revenue exceeding the level prescribed in Clause 1 of this Article;

b) Distribution and supply of goods: tax rate 0.5%;

c) Services, construction excluding materials: tax rate 2%. Specifically, for asset leasing, insurance agency, lottery agency, multi-level marketing sales agency activities: tax rate 5%;

d) Production, transportation, services attached to goods, construction including materials: tax rate 1.5%;

đ) Activities providing digital information content products and services about entertainment, video games, digital films, digital photos, digital music, digital advertising: tax rate 5%;

e) Other business activities: tax rate 1%.

4. Individuals leasing real estate, except for accommodation business operations, shall pay personal income tax calculated by multiplying (x) the portion of revenue exceeding the level prescribed in Clause 1 of this Article with a tax rate of 5%.

5. The Government shall provide detailed regulations on this matter.

Article 8. Personal Income Tax on Income from Wages and Salaries

1. Personal income tax on income from wages and salaries of resident individuals is determined by multiplying the taxable income as stipulated in Clause 2 of this Article by the progressive tax rate table prescribed in Article 9 of this Law, regardless of the place where the income is paid.

2. Taxable income from wages and salaries is the total taxable income as stipulated in Clause 2 of Article 3 of this Law received by the taxpayer during the tax period, minus (-) contributions to social insurance, health insurance, unemployment insurance, occupational liability insurance for certain industries and professions required to participate in mandatory insurance, contributions to supplementary pension insurance as prescribed by the Social Insurance Law, voluntary pension insurance, life insurance not exceeding the limit set by the Government, and deductions as prescribed in Articles 10 and 11 of this Law.

3. The time for determining taxable income from wages and salaries is the time when the organization or individual pays income to the taxpayer or the time when the taxpayer receives the income.

Article 9. Progressive Tax Rate Table

1. The progressive tax rate table applies to taxable income as stipulated in Clause 2 of Article 8 of this Law.

2. The progressive tax rate table is defined as follows:

Article 10. Household Deduction

1. Household deduction is the amount deducted from taxable income before calculating personal income tax on income from wages and salaries of resident individuals. Household deduction includes:

a) The deduction level for the taxpayer is 15.5 million dong/month (186 million dong/year);

b) The deduction level for each dependent is 6.2 million dong/month.

2. Based on fluctuations in prices, income, the Government shall submit to the Standing Committee of the National Assembly to regulate the household deduction level prescribed in Clause 1 of this Article in accordance with economic and social conditions in each period.

3. The determination of household deduction for dependents shall be based on the principle that each dependent can only be deducted once from one taxpayer.

4. Dependents are persons whom the taxpayer has the responsibility to support, including:

a) Minor children; children who have lost civil capacity, disabled persons, and those unable to work;

b) Individuals without income or with income not exceeding the level prescribed by the Minister of Finance, including adult children currently studying at university, college, vocational high school, or vocational training; spouses who are unable to work; parents who have exceeded the working age or are unable to work; other people without support who must be directly supported by the taxpayer.

Article 11. Deductions for Charitable Contributions and Other Deductions

Resident individuals are entitled to deduct from taxable income before calculating personal income tax on income from wages and salaries the following items:

1. Charitable and humanitarian contributions, including:

a) Contributions to organizations and facilities caring for and nurturing children in difficult circumstances, disabled persons, and elderly people without support;

b) Contributions to charitable funds, humanitarian funds, educational funds;

c) Contributions to organizations with fundraising functions established and operating in accordance with the law.

Organizations, facilities, and funds prescribed in this Clause must be permitted to establish or recognized by competent state authorities and operate for charitable, humanitarian, and educational purposes, not for profit.

2. Expenses for healthcare and education-training of taxpayers and their dependents are deductible from income before taxation at levels prescribed by the Government.

3. Expenses prescribed in this Article must meet the requirements of invoices and receipts under the law and cannot be paid from other sources.

4. The Government shall provide detailed regulations on this matter.

Article 12. Personal Income Tax on Income from Capital Investment

1. Tax on income from capital investment of resident individuals is determined by multiplying taxable income by a tax rate of 5%.

2. Taxable income from capital investment is the total taxable income from capital investment as stipulated in Clause 3 of Article 3 of this Law received by the taxpayer each time it occurs.

3. The time for determining taxable income from capital investment is the time when the organization or individual pays income to the taxpayer or the time when the taxpayer receives the income.

4. The Government shall provide detailed regulations on this matter.

Article 13. Personal Income Tax on Income from Transfer of Capital

1. Personal income tax on income from the transfer of capital of resident individuals is determined by multiplying taxable income (x) with a tax rate of 20% for each transfer. In this case, taxable income from the transfer of capital is determined by subtracting (−) the purchase price and reasonable expenses related to generating income from the transfer of capital from the transfer price.

In cases where the purchase price and expenses related to the transfer of capital cannot be determined, personal income tax is determined by multiplying the transfer price (x) with a tax rate of 2%.

2. Personal income tax on income from the transfer of securities is determined by multiplying the transfer price (x) with a tax rate of 0.1% for each transfer.

3. The time point for determining taxable income is the completion of the transaction according to the provisions of the law.

4. The Government shall provide detailed regulations on this matter.

Article 14. Personal income tax on income from the transfer of real estate

1. Personal income tax on income from the transfer of real estate of resident individuals is determined by multiplying the transfer price (x) with a tax rate of 2%.

2. The time point for determining taxable income from the transfer of real estate is the time when the transfer contract becomes effective according to the provisions of the law or the time of registration of the right to use, ownership of real estate.

3. The Government shall provide detailed regulations on this Article.

Article 15. Personal income tax on income from lottery winnings

1. Personal income tax on income from lottery winnings of resident individuals is determined by multiplying taxable income (x) with a tax rate of 10%.

2. Taxable income from lottery winnings is the portion of the prize value exceeding 20 million dong that the taxpayer receives per winning event.

3. The time point for determining taxable income from lottery winnings is the time when the organization or individual pays income to the taxpayer.

Article 16. Personal income tax on income from royalties

1. Personal income tax on income from royalties of resident individuals is calculated by multiplying taxable income (x) with a tax rate of 5%.

2. Taxable income from royalties is the portion of income exceeding 20 million dong that the taxpayer receives when transferring, licensing the use of intellectual property objects, or transferring technology per contract.

3. The time point for determining taxable income from royalties is the time when the organization or individual pays income to the taxpayer.

Article 17. Personal income tax on income from franchising

1. Personal income tax on income from franchising of resident individuals is calculated by multiplying taxable income (x) with a tax rate of 5%.

2. Taxable income from franchising is the portion of income exceeding 20 million dong that the taxpayer receives per franchising contract.

3. The time point for determining taxable income from franchising is the time when the organization or individual pays income to the taxpayer.

Article 18. Personal income tax on income from inheritance and gifts

1. Personal income tax on income from inheritance and gifts of resident individuals is determined by multiplying taxable income (x) with a tax rate of 10%.

2. Taxable income from inheritance and gifts is the portion of the inherited asset value or gift exceeding 20 million dong that the taxpayer receives per occurrence.

3. The time point for determining taxable income is specified as follows:

a) For income from inheritance, it is the time when the taxpayer receives the inheritance;

b) For income from gifts, it is the time when the organization or individual gives the gift to the taxpayer or the time when the taxpayer receives the income.

4. The Government shall provide detailed regulations on this matter.

Article 19. Personal income tax on other income

1. Personal income tax on other income of resident individuals as stipulated in points a, b, and c Clause 10 Article 3 of this Law is determined by multiplying taxable income (x) with a tax rate of 5%. In this case, taxable income is the portion of income exceeding 20 million dong that the taxpayer receives per occurrence.

2. Personal income tax on other income of resident individuals as stipulated in points d and đ Clause 10 Article 3 of this Law is determined by multiplying the transfer price (x) with a tax rate of 0.1%.

3. The time point for determining taxable income is the time when the organization or individual pays income to the taxpayer or the time when the taxpayer receives the income.

4. The Government shall provide detailed regulations on this matter.

Chapter III

BASIS FOR CALCULATING TAX FOR NON-RESIDENTS

Article 20. Personal income tax on income from business operations

1. Personal income tax on income from business operations of non-resident individuals is determined by multiplying the business revenue from the business activities specified in Clause 2 of this Article (x) with the tax rate specified in Clause 3 of this Article.

2. Business revenue includes all money from selling goods, processing fees, service fees including subsidies, surcharges, premiums that the individual enjoys, regardless of whether the money has been received or not, including costs paid by the buyer of goods or services on behalf of the non-resident individual without reimbursement.

In cases where the contract agreement does not include personal income tax, the taxable business revenue must be converted to the total amount of money that the non-resident individual receives in any form from providing goods or services in Vietnam, regardless of the location where the business activities take place.

3. Tax rates:

a) Distribution, supply of goods: 1%;

b) Services, construction excluding materials: 5%;

c) Production, transportation, services attached to goods, construction including materials: 2%;

d) Activities providing digital content products and services such as entertainment, video games, digital films, digital photos, digital music, advertising: 5%;

đ) Other business activities: 2%.

Article 21. Personal income tax on income from salaries and wages

Personal income tax on income from salaries and wages of non-resident individuals is determined by multiplying the total salary and wage amounts that the non-resident individual receives for performing work in Vietnam (x) with a tax rate of 20%, regardless of the place of payment of income.

Article 22. Personal income tax on income from investment capital

Individual income tax on income from capital investment by non-resident individuals is determined by multiplying the total income received from capital investment in organizations and individuals in Vietnam by (x) with a tax rate of 5%.

Article 23. Individual income tax on income from transfer of capital

1. Individual income tax on income from the transfer of capital by non-resident individuals is determined by multiplying taxable income by (x) with a tax rate of 20% for each occurrence, regardless of whether the transfer takes place in Vietnam or abroad. In this case, taxable income from the transfer of capital is determined by subtracting (-) the purchase price and reasonable related expenses from the transfer price to generate income from transferring capital in organizations and individuals in Vietnam.

In cases where the purchase price and related expenses cannot be determined, individual income tax is calculated by multiplying the transfer price of capital in organizations and individuals in Vietnam by (x) with a tax rate of 2%.

2. Individual income tax on income from the transfer of securities by non-resident individuals is determined by multiplying the transfer price by (x) with a tax rate of 0.1%.

3. The Government shall provide detailed regulations on this Article.

Article 24. Individual income tax on income from the transfer of real estate

1. Individual income tax on income from the transfer of real estate by non-resident individuals is determined by multiplying the transfer price by (x) with a tax rate of 2%.

2. The Government shall provide detailed regulations for this Article.

Article 25. Individual income tax on income from royalties and franchise fees

1. Individual income tax on income from royalties by non-resident individuals is determined by multiplying the portion of income exceeding 20 million VND per contract for the transfer or assignment of intellectual property rights and technology transfer in Vietnam by (x) with a tax rate of 5%.

2. Individual income tax on income from franchise fees by non-resident individuals is determined by multiplying the portion of income exceeding 20 million VND per franchise agreement in Vietnam by (x) with a tax rate of 5%.

Article 26. Individual income tax on income from winnings, inheritance, and gifts

Individual income tax on income from winnings, inheritance, and gifts by non-resident individuals is determined by multiplying the value exceeding 20 million VND per occurrence of winnings, inheritance, and gifts in Vietnam by (x) with a tax rate of 10%.

Article 27. Individual income tax on other income

1. Individual income tax on other income of non-resident individuals as specified in points a, b, and c of Clause 10, Article 3 of this Law is determined by multiplying taxable income by (x) with a tax rate of 5%. Taxable income is the portion of income exceeding 20 million VND received by the taxpayer per occurrence.

2. Individual income tax on other income of non-resident individuals as specified in points d and đ of Clause 10, Article 3 of this Law is determined by multiplying the transfer price by (x) with a tax rate of 0.1%.

3. The Government shall provide detailed regulations on this Article.

Article 28. Time of determination of taxable income

1. The time of determination of taxable income for income as stipulated in Article 20 of this Law is the time when the non-resident individual receives the income or the time when the sales invoice for goods sold or services provided is issued.

2. The time of determination of taxable income for income as stipulated in Articles 21, 22, 25, 26, and 27 of this Law is the time when organizations and individuals in Vietnam pay income to non-resident individuals or the time when non-resident individuals receive the income.

3. The time of determination of taxable income for income as stipulated in Article 23 of this Law is the time when the transaction is completed according to the provisions of the law.

4. The time of determination of taxable income for income as stipulated in Article 24 of this Law is the time when the transfer contract becomes effective according to the provisions of the law or the time of registration of the right to use or ownership of real estate.

5. The Government shall provide detailed regulations on this matter.

Chapter IV

IMPLEMENTING PROVISIONS

Article 29. Implementation Provisions

1. This Law shall take effect from July 1, 2026, except for the provisions in Clause 2 of this Article.

2. Regulations related to income from business operations, salaries, and wages of resident individuals shall apply from the 2026 tax year.

3. The Personal Income Tax Law No. 04/2007/QH12, which has been amended and supplemented by Laws No. 26/2012/QH13, No. 71/2014/QH13, No. 31/2024/QH15, No. 48/2024/QH15, No. 56/2025/QH15, No. 71/2025/QH15, and No. 93/2025/QH15 shall cease to be effective from the date this Law comes into force; however, regulations related to income from business operations, salaries, and wages of resident individuals shall cease to be effective from the 2026 tax year.

4. Where there are different provisions regarding tax incentives between this Law and the Law on the Capital City, resolutions of the National Assembly, and measures prescribed in point h of Clause 8, Article 10 of the Law on the Organization of the Government, the provisions of the Law on the Capital City, resolutions of the National Assembly, and measures prescribed in point h of Clause 8, Article 10 of the Law on the Organization of the Government shall apply. If the provisions of this Law offer more favorable treatment, the taxpayer may choose to apply the most beneficial incentive.

This Law was adopted by the National Assembly of the Socialist Republic of Vietnam, the 10th Session of the 15th Legislature, on December 10, 2025.