Circular No. 32/2026/TT-BTC Guiding Value Added Tax, Enterprise Income Tax and Individual Income Tax for Transactions, Transfer, and Trading of Digital Assets in Vietnam

CIRCULAR

Guidance on Value Added Tax, Enterprise Income Tax, and Individual Income Tax for Transactions, Transfer of Digital Assets, and Trading in Digital Assets

______________

Based on the Enterprise Income Tax Law No. 67/2025/QH15;

Based on the Value Added Tax Law No. 48/2024/QH15 amended and supplemented by the Laws Nos. 90/2025/QH15 and 149/2025/QH15;

Based on the Individual Income Tax Law No. 04/2007/QH12 amended and supplemented by the Laws Nos. 26/2012/QH12, 71/2014/QH13, and 56/2024/QH15;

Based on Decree No. 320/2025/NĐ-CP of the Government detailing certain provisions and measures to organize and guide the implementation of the Enterprise Income Tax Law;

Based on Decree No. 181/2025/NĐ-CP of the Government detailing certain provisions of the Value Added Tax Law amended and supplemented by Decree No. 359/2025/NĐ-CP;

Based on Decree No. 65/2013/NĐ-CP of the Government detailing certain provisions of the Individual Income Tax Law and the Decree amending and supplementing certain provisions of the Individual Income Tax Law amended and supplemented by Decree No. 12/2015/NĐ-CP;

Based on Resolution No. 05/2025/NQ-CP of the Government on the implementation of a pilot market for digital assets in Vietnam;

Based on Decree No. 29/2025/NĐ-CP of the Government on the functions, powers, and organizational structure of the Ministry of Finance amended by Decree No. 166/2025/NĐ-CP;

In accordance with the proposal of the Director of the Department of Tax Policy and Fee Supervision;

The Minister of Finance promulgates this Circular to guide value added tax, enterprise income tax, and individual income tax for transactions, transfer, and trading in digital assets.

Article 1. Scope of Application

This Circular guides the application of value added tax, enterprise income tax, and individual income tax, including the determination of revenue and income for transactions, transfers, and trading in digital assets as provided in Resolution No. 05/2025/NQ-CP dated September 9, 2025, by the Government on the implementation of a pilot market for digital assets in Vietnam.

Article 2. Applicability

This Circular applies to organizations and individuals related to the scope of application as provided in Article 1 of this Circular.

Article 3. Value Added Tax Policy

1. The transfer, trading of digital assets are not subject to value added tax.

2. For activities not specified in paragraph 1 of this Article, the provisions of the Value Added Tax Law shall apply.

Article 4. Enterprise Income Tax Policy

1. Investors who are organizations established and operating in accordance with Vietnamese law and generating income from the transfer of digital assets subject to enterprise income tax at a rate of 20%, except as provided in paragraphs 2 and 3 of Article 10 of the Enterprise Income Tax Law No. 67/2025/QH15. The taxable income from the transfer of digital assets for each period is determined by subtracting the purchase price of the transferred digital asset and related expenses with valid invoices or receipts as provided.

2. Enterprises providing services in digital assets in accordance with paragraph 3 of Article 3 of Resolution No. 05/2025/NQ-CP generating income from such activities subject to enterprise income tax at a rate of 20%, except as provided in paragraphs 2 and 3 of Article 10 of the Enterprise Income Tax Law No. 67/2025/QH15.

3. Investors who are organizations established under foreign law engaging in the transfer of digital assets through an enterprise providing services in digital assets subject to enterprise income tax at a rate of 0.1% on the transferred amount per transaction.

Article 5. Personal Income Tax Policy

Investors who are individuals (whether resident or non-resident) engaging in the transfer of virtual assets through an organization providing virtual asset services and falling within the scope of personal income tax payers shall be subject to a tax rate of 0.1% on the transfer price for each transaction.

Article 6. Determination of Revenue, Income

The determination of revenue and income in respect of the transfer of virtual assets shall be carried out in accordance with the provisions of the Enterprise Income Tax Law and Personal Income Tax Law regarding the determination of revenue and income from the transfer of securities, as well as the law on virtual assets.

Article 7. Enforceability

1. This Circular takes effect from March 27, 2026, and shall be implemented in accordance with the pilot implementation provisions specified in Clause 2 and Clause 3 of Article 18 of Resolution No. 05/2025/NQ-CP or until such time as a personal income tax policy for the virtual asset market is provided for in Clause 9 of Article 4 of Resolution No. 05/2025/NQ-CP.

2. Where no guidance is provided herein, implementation shall be in accordance with the current tax laws.