Law on Corporate Income Tax No. 67/2025/QH15

LAW

ENTERPRISE INCOME TAX

On the basis of the Constitution of the Socialist Republic of Vietnam;

The National Assembly enacts the Enterprise Income Tax Law.

PART I

GENERAL PROVISIONS

Article 1. Scope of Regulation

This Law provides for taxpayers, taxable income, exempted income, tax base, tax calculation methods, and enterprise income tax incentives.

Article 2. Taxpayer

1. Taxpayers of enterprise income tax are organizations engaged in production and business activities generating taxable income as provided for in this Law (hereinafter referred to as enterprises), including:

a) Enterprises established in accordance with Vietnamese laws;

b) Enterprises established in accordance with foreign laws (hereinafter referred to as foreign enterprises) having a permanent establishment or not having a permanent establishment in Vietnam;

c) Cooperatives and cooperative unions established in accordance with the Law on Cooperatives;

d) Public service units established in accordance with Vietnamese laws;

đ) Other organizations engaging in production and business activities generating income.

2. Enterprises generating taxable income as stipulated in Article 3 of this Law must pay enterprise income tax as follows:

a) Enterprises established in accordance with Vietnamese laws shall pay tax on taxable income generated in Vietnam and taxable income generated outside Vietnam;

b) Foreign enterprises having a permanent establishment in Vietnam shall pay tax on taxable income generated in Vietnam and taxable income generated outside Vietnam related to the activities of such permanent establishment;

c) Foreign enterprises having a permanent establishment in Vietnam shall pay tax on taxable income generated in Vietnam that is not related to the activities of such permanent establishment;

d) Foreign enterprises without a permanent establishment in Vietnam, including e-commerce businesses and businesses based on digital platforms, shall pay tax on taxable income generated in Vietnam.

3. A permanent establishment of a foreign enterprise is a production or business facility through which the foreign enterprise conducts part or all of its production and business activities in Vietnam, including:

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

b) Construction sites, construction projects, installation, assembly;

c) Service-providing facilities, including consulting services provided through employees or other individuals or organizations;

d) Agents for foreign enterprises;

đ) Representatives in Vietnam where they are authorized representatives signing contracts on behalf of foreign enterprises or non-authorized representatives frequently conducting transactions of goods or services in Vietnam;

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

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

Article 3. Taxable Income

1. Taxable income under enterprise income tax includes income from production and business activities of goods and services and other income as stipulated in Clause 2 of this Article.

2. Other income includes:

a) Income from capital transfer, equity contribution transfer, securities transfer;

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

c) Income from investment project transfer, participation rights in investment projects transfer, exploration, exploitation, processing mineral rights transfer;

d) Income from asset sale, lease, liquidation, including negotiable instruments, except real estate;

đ) Income from property usage rights, ownership rights, including intellectual property rights income, technology transfer income;

e) Income from deposit interest, loan interest, foreign currency sales, except income from credit operations of credit institutions;

g) Pre-expensed amounts not used or not fully used that the enterprise does not adjust to reduce deductible expenses; bad debts written off but recovered; unidentifiable creditor debts; income from business activities in previous years that were overlooked but now discovered;

h) Differences between penalties received, compensation received due to economic contract violations or bonuses received for fulfilling contract commitments;

i) Grants and donations received in cash or in kind;

k) Differences arising from revaluation of assets according to the law for capital contributions, transfers during mergers, consolidations, divisions, changes in ownership, changes in business forms;

l) Income from joint venture contracts;

m) Income from production and business activities abroad;

n) Income of public service units from leasing state assets;

o) Other income, except income exempted from tax as stipulated in Article 4 of this Law.

3. Taxable income generated in Vietnam of foreign enterprises as stipulated in point c, point d, Clause 2, Article 2 of this Law is income received from sources in Vietnam, regardless of the location of business operations.

4. Vietnamese enterprises investing abroad that generate income from production and business activities abroad during the tax period may deduct the amount of enterprise income tax payable according to the regulations of the host country from the amount of enterprise income tax payable in Vietnam, but not exceeding the amount of enterprise income tax calculated according to the provisions of the Vietnamese law on enterprise income tax.

5. If enterprises are required to pay additional enterprise income tax on consolidated minimum taxable income (IIR) as prescribed by law, the additional enterprise income tax payable can be deducted from the amount of enterprise income tax payable in Vietnam according to this Law.

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

1. Income from fishing activities; income of enterprises from producing agricultural products, planted forests, livestock breeding, aquaculture, processing agricultural and aquatic products (including cases where agricultural and aquatic products are purchased for processing) in areas with special difficulties in socio-economic conditions; income of cooperatives and cooperative unions from producing agricultural products, planted forests, livestock breeding, aquaculture, processing agricultural and aquatic products (including cases where agricultural and aquatic products are purchased for processing), salt production.

2. Income of cooperatives and cooperative unions operating in agriculture, forestry, fisheries, and salt industries in areas with difficulties in socio-economic conditions or in areas with special difficulties in socio-economic conditions.

3. Income from directly providing technical services to serve agriculture.

4. Income from performing research contracts, scientific development, innovation, and digital transformation; income from selling products made using new technology applied for the first time in Vietnam; income from selling experimental products during the experimental production period, including controlled experimental production according to the law. The income under this clause is exempted from tax for a maximum of three years.

5. Income from production and business activities of enterprises employing at least 30% of their average annual workforce as persons with disabilities, former drug addicts, HIV/AIDS patients, and having an average annual workforce of twenty people or more, excluding financial and real estate businesses.

7. Dividends received from capital contribution, share purchase, joint venture, and association with domestic enterprises, after paying corporate income tax according to this Law, including cases where the recipient of capital contribution, share issuance, joint venture, and association enjoys corporate income tax incentives.

8. Grants received for use in educational, cultural, artistic, charitable, humanitarian, and other social activities in Vietnam; grants received from non-associated enterprises, organizations, and individuals both domestically and internationally for use in scientific research, technological development, innovation, and digital transformation; direct support from the state budget and the investment support fund established by the Government; compensation from the State according to the law.

In case the enterprise uses the grants received under this clause for purposes other than those intended, it shall be subject to tax recovery and penalties according to the law.

9. The difference in asset valuation according to the law for corporate restructuring and reorganization of enterprises wholly owned by the State.

10. Income from transferring emission reduction certificates, carbon credit transfers for the first time after issuance by enterprises granted emission reduction certificates, carbon credits; income from green bond interest; income from transferring green bonds for the first time after issuance.

11. Income (including bank deposit interest, government bond interest, treasury bill interest) from performing state-assigned tasks in the following cases:

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

b) Income of the Social Policy Bank from lending to the poor and other policy beneficiaries;

c) Income of the Limited Liability Company managing assets of Vietnamese credit institutions;

d) Income from revenue-generating activities of state financial funds and other state organizations operating without profit-making objectives as prescribed or decided by the Government or the Prime Minister.

12. The portion of undistributed income of entities implementing socialization in education-training, healthcare, and other socialized fields left for developing such entities, meeting the minimum ratio prescribed by the Government; the portion of undistributed common fund and undistributed common property of cooperatives and cooperative unions established and operated according to the law on cooperatives.

13. Income from transferring technology in priority technology transfer fields to organizations and individuals in areas with special difficulties in socio-economic conditions.

14. Income of public service units from providing public service activities, including:

a) Basic and essential public services within the list of public services funded by the state budget issued by competent authorities;

b) Public services that the State must support and ensure operational funding due to insufficient cost coverage in service prices;

c) Public services in areas with special difficulties in socio-economic conditions.

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

Article 5. Tax Period

1. The tax period for corporate income tax is determined according to the Gregorian calendar year or the fiscal year chosen by the enterprise, except in cases provided for in Clause 2 of this Article. If the enterprise chooses a fiscal year different from the Gregorian calendar year, it must notify the direct tax administration authority before implementation.

2. The tax period for enterprises specified in points c and d of Clause 2 of Article 2 of this Law shall be implemented in accordance with the provisions of the law on tax administration.

Chapter II
BASIS AND METHOD OF CALCULATING TAX

Article 6. Basis for calculating tax

The basis for calculating tax is taxable income and tax rate.

Article 7. Determination of Taxable Income

1. Taxable income during the tax period is determined as follows:

Taxable income = Taxable income - (Tax-exempt income + Losses carried forward as prescribed)

2. Taxable income as stipulated in Clause 1 of this Article is determined as follows:

Taxable income = Revenue - Deductible expenses + (including income received from abroad) - Other income

3. For enterprises engaged in multiple production and business activities during the tax period, taxable income from production and business activities is the total revenue from all such activities. In case there are production and business activities that incur losses, the losses can be offset against the taxable income of other production and business activities with income, as selected by the enterprise (except for income from real estate transfer, investment project transfer, and participation rights transfer in investment projects which cannot be offset against the taxable income of ongoing production and business activities enjoying tax incentives). The remaining income after offsetting is subject to the corporate income tax rate applicable to the production and business activities still generating income.

4. Taxable income from transferring investment projects for exploration, exploitation, and processing of minerals; transferring participation rights in such projects must be separately determined for declaration and payment of taxes, and cannot be offset against profits or losses from production and business activities during the tax period.

Article 8. Revenue

1. Revenue for determining taxable income includes all proceeds from sales, processing fees, service provision fees including subsidies, surcharges, and premiums that the enterprise enjoys, regardless of whether the money has been collected or not.

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

a) Actual expenditures incurred in connection with the production and business operations of the enterprise, including additional deductible expenses calculated as a percentage of actual expenditures incurred during the tax period related to the enterprise’s research and development activities;

b1) Expenses for implementing national defense and security education tasks, training, and activities of civilian self-defense forces and serving other national defense and security missions as prescribed by law;

b2) Expenses supporting the activities of party organizations and political-social organizations within enterprises;

b3) Expenses for vocational education and training of workers as prescribed by law;

b4) Actual expenses for HIV/AIDS prevention and control activities at the workplace of the enterprise;

b5) Sponsorship for education, healthcare, culture; sponsorship for disaster relief, epidemic prevention, construction of solidarity houses, benevolent houses, and houses for policy beneficiaries as prescribed by law; sponsorship as prescribed by the Government and Prime Minister for localities in particularly difficult economic and social conditions; sponsorship for scientific research, technological development, and innovation, digital transformation;

b6) Expenses for scientific research, technological development, innovation, and digital transformation;

b7) Losses due to natural disasters, epidemics, and other force majeure situations that are not compensated;

b8) Actual expenses for personnel dispatched to manage, operate, and supervise special-control credit institutions and compulsorily transferred commercial banks as prescribed by the Law on Credit Institutions;

b9) Certain expenses serving production and business operations of enterprises but not corresponding to revenue generated during the period as prescribed by the Government;

b10) Certain expenses supporting the construction of public works while also serving the production and business operations of enterprises;

b11) Costs related to reducing greenhouse gas emissions to achieve carbon neutrality and net-zero, reducing environmental pollution, and related to the production and business operations of enterprises;

b12) Certain contributions to funds established by decisions of the Prime Minister and regulations of the Government;

2. Expenses not deductible when determining taxable income include:

a) Expenses that do not meet the conditions prescribed in Clause 1 of this Article;

b) Administrative fines;

c) Expenses reimbursed by other sources;

d) Excess expenses over the limits set by the Government for: management costs allocated by foreign enterprises to their permanent establishments in Vietnam; costs for managing electronic gaming and casino operations; interest payments on loans of enterprises with related-party transactions; welfare expenses directly benefiting employees; contributions to supplementary pension insurance schemes under the Social Insurance Law or social welfare funds, voluntary pension insurance, and life insurance for employees;

đ) Excessive or incorrect provisions for reserves as prescribed by law;

e) Incorrect or excessive depreciation of fixed assets as prescribed by law;

g) Incorrect pre-provisioning of expenses as prescribed by law;

h) Wages and salaries of individual owners of private enterprises, single-member limited liability companies owned by individuals; remuneration paid to founders who do not directly participate in management and operation; wages, salaries, and other accounting entries for employee payments that were not actually made or lack legal invoices and supporting documents;

i) Interest payments on loans corresponding to the shortfall in subscribed capital; interest on loans during the investment period already recorded in the investment value; interest on loans for implementing exploration, search, and oil extraction contracts; interest payments on production and business loans of non-credit institution entities exceeding the limits prescribed by the Civil Code.

k) The portion of costs allowed to be recovered exceeding the ratio specified in the approved oil and gas contract; in cases where the oil and gas contract does not specify the recovery ratio, the portion of costs exceeding the level prescribed by the Government shall not be included in deductible expenses;

l) The portion of input value-added tax that has been deducted; value-added tax paid under the deduction method; input value-added tax on the portion of the value of passenger cars with up to nine seats exceeding the level prescribed by the Government; corporate income tax; other taxes, fees, and charges that are not included in deductible expenses as stipulated by law and late payment penalties as prescribed by law on tax management;

The portion of value-added tax paid under the deduction method as provided for herein does not include the portion of input value-added tax on goods and services directly related to the production and business operations of the enterprise which have not yet been fully deducted but do not fall within the circumstances eligible for refund;

Input value-added tax when already included in deductible expenses shall not be deducted from output value-added tax;

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

n) Grants, except for grants specified in sub-point b5 point b clause 1 of this Article;

o) Expenditure on basic construction investment during the investment phase to form fixed assets; expenditure directly related to changes in the owner's equity of the enterprise;

p) Expenditures of business activities: banking, insurance, lottery, securities, BT, BOT, BTO contracts not in accordance with or exceeding the limits prescribed by law;

q) Other expenditures.

3. The Government shall provide detailed regulations on this matter, including additional expenditure levels, conditions, timeframes, and scope of application for the expenditure for research and development activities of enterprises as specified in point a clause 1 of this Article.

The Ministry of Finance shall prescribe the documentation for expenditures included in deductible expenses as specified in points b and c clause 1 of this Article.

Article 10. Tax Rate

1. The corporate income tax rate is 20%, except for cases specified in clauses 2, 3, and 4 of this Article and for taxpayers eligible for preferential tax rates as stipulated in Article 13 of this Law.

2. A tax rate of 15% applies to enterprises with annual total revenue not exceeding three billion VND.

3. A tax rate of 17% applies to enterprises with annual total revenue from more than three billion VND to not exceeding fifty billion VND.

Revenue serving as the basis for determining enterprises eligible for the tax rates of 15% and 17% as specified in clauses 2 and 3 of this Article is the total revenue of the preceding tax period for corporate income tax. The determination of total revenue for application purposes shall be carried out according to the regulations of the Government.

4. The corporate income tax rate for certain other cases is prescribed as follows:

a) For exploration, development, and extraction of oil and gas, the rate ranges from 25% to 50%. Based on the location, exploitation conditions, and reserves of the field, the Prime Minister decides the specific tax rate applicable to each oil and gas contract;

b) For exploration and extraction of rare mineral resources (including platinum, gold, silver, tin, tungsten, antimony, precious stones, rare earths, and other rare minerals as prescribed by law), the rate is 50%. In cases where 70% or more of the area of the mine is located in areas with extremely difficult socio-economic conditions, the tax rate is 40%.

Article 11. Method of Calculating Tax

1. The amount of corporate income tax payable in the tax period is calculated by multiplying the taxable income by the tax rate, except in cases specified in clause 2 of this Article.

2. The Government shall prescribe the amount of corporate income tax payable based on a percentage of revenue for the following cases:

a) Enterprises specified in points c and d clause 2 of Article 2 of this Law; taxpayers performing the obligation to declare and pay taxes, the time and manner of determining revenue from taxable income generated in Vietnam;

b) Enterprises with annual total revenue not exceeding three billion VND as specified in clause 2 of Article 10 of this Law in cases where revenue can be determined but costs and income from production and business operations cannot be determined;

c) Cooperatives, cooperative unions, public institutions, and other organizations specified in points c, d, and e clause 1 of Article 2 of this Law that engage in production and business operations generating corporate income tax revenue (excluding income exempted from tax as stipulated in Article 4 of this Law) where these entities can account for revenue but cannot determine costs and income from production and business operations.

Chapter III

TAX INCENTIVES FOR CORPORATE INCOME TAX

Article 12. Principles and objects of application for corporate income tax incentives

1. Enterprises shall enjoy corporate income tax incentives according to industries and occupations with preferential corporate income tax, and areas with preferential corporate income tax as stipulated in this Article. The level of corporate income tax incentives shall be implemented in accordance with the provisions of Articles 13 and 14 of this Law.

In cases where other laws provide different regulations on corporate income tax incentives compared to the provisions of this Law, such regulations shall be implemented in accordance with the provisions of this Law, except for the Law on the Capital City and resolutions providing special mechanisms and policies as determined by the National Assembly.

Within the same period, if an enterprise enjoys multiple levels of tax incentives under the provisions of this Law for the same income, the enterprise may choose to apply the most favorable tax incentive level.

2. Industries and occupations with preferential corporate income tax include:

a) High-tech applications, venture capital investments for high-tech development within the priority investment development list of high technologies as prescribed by the Law on High Technology; strategic technology applications as prescribed by law; high-tech incubation, high-tech enterprise incubation; investment in constructing and operating high-tech incubation facilities, high-tech enterprise incubation facilities;

b) Production of software products; production of network security products and provision of network security services ensuring conditions as prescribed by law on network security; production of key digital technology products and services, electronic device production as prescribed by law on digital industry; research and development, design, production, packaging, testing of semiconductor products; construction of artificial intelligence data centers;

c) Production of supporting industrial products listed in the Priority Development List of Supporting Industrial Products prescribed by the Government that meet one of the following criteria:

c1) Supporting industrial products for high technology as prescribed by the Law on High Technology;

c2) Supporting industrial products for textile - garment, leather - shoe, electronics - information technology (including semiconductor design and production), automobile manufacturing and assembly, mechanical manufacturing up to the date this Law comes into effect, which have not been produced domestically or have been produced but must meet European Union technical standards or equivalent standards (if applicable) as prescribed by the Minister of Industry and Trade;

d) Renewable energy production, clean energy, energy from waste disposal; environmental protection; composite material production, lightweight building materials, rare materials; national defense, security product production and industrial mobilization product production as prescribed by law on national defense, security, and industrial mobilization; key chemical industry product production and key machinery product production as prescribed by law;

đ) Investment in developing water treatment plants, power plants, water supply and drainage systems, roads, railways, airports, seaports, inland ports, airfields, railway stations, and other particularly important infrastructure projects as decided by the Prime Minister;

e) High-tech enterprises, agricultural enterprises applying high technology as prescribed by the Law on High Technology; science and technology enterprises as prescribed by the Law on Science, Technology, and Innovation;

g) Investment projects in production fields meeting the following conditions:

g1) Having a minimum investment capital scale of 120 trillion VND and implementing disbursement of the total registered investment capital within no more than five years from the date of permission to invest as prescribed by law on investment;

g2) Using technology that meets requirements as prescribed by the Minister of Science and Technology;

h) Investment projects falling under the preferential and special investment support objects prescribed in Clause 2, Article 20 of the Investment Law. The Government shall specify detailed regulations on the implementation time for disbursement of the total registered investment capital of projects prescribed in this point;

i) Planting, caring for, and protecting forests; production, breeding, and hybridizing crop and livestock seeds; investment in post-harvest agricultural product preservation, food preservation, and seafood preservation; salt production, refining, and extraction, excluding salt production as prescribed in Clause 1, Article 4 of this Law;

k) Cultivation of forest products;

l) Agricultural crop products, planted forests, animal husbandry, aquaculture, agricultural and seafood processing;

Income from agricultural and seafood processing as prescribed in this point must comply with the conditions prescribed in Clause 1, Article 4 of this Law;

m) High-quality steel production; energy-saving product production; production of machinery and equipment serving agriculture, forestry, fisheries, and salt production; irrigation equipment production; feed production for livestock, poultry, and aquaculture;

n) Automobile production and assembly; production of other digital technology products;

o) Operating technical support bases for small and medium-sized enterprises, enterprise incubation bases; operating shared working spaces supporting innovative startups of small and medium-sized enterprises as prescribed by the Law on Support for Small and Medium-Sized Enterprises;

p) People's Credit Funds, microfinance organizations, cooperative banks;

q) Cooperatives and cooperative unions operating in agriculture, forestry, fisheries, and salt production;

r) Socialization in education and training, vocational training, healthcare, culture, sports, and environment sectors as prescribed in the List of Types, Scale Criteria, and Standards decided by the Prime Minister; judicial appraisal;

s) Investment in building social housing for sale, lease, or lease-purchase for eligible recipients of social housing support as prescribed by the Law on Housing;

t) Publishing as prescribed by the Law on Publishing;

u) Press (including advertising in newspapers) as prescribed by the Law on Press.

3. Areas with preferential corporate income tax are prescribed by the Government, including:

a) Areas with extremely difficult socio-economic conditions;

b) Areas with difficult socio-economic conditions;

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

4. The Government shall prescribe the application of tax incentives for the following cases:

a) Cases applying tax incentives based on area criteria;

b) The case of tax incentives in the agricultural, forestry, fishery, and salt industries;

c) The case where, in the first taxable period, there is revenue or income from investment projects of enterprises (including new investment projects, expanded investment projects, high-tech enterprises, advanced technology application agriculture enterprises, science and technology enterprises) with a time frame for generating revenue or income eligible for tax incentives under 12 months.

5. Enterprises established or enterprises having investment projects from mergers, consolidations, divisions, spin-offs, or changes in ownership or business form shall be responsible for fulfilling their corporate income tax obligations (including penalties if applicable), while inheriting corporate income tax incentives (including untransferred losses) of the enterprise or investment project prior to mergers, consolidations, divisions, spin-offs, or changes if they continue to meet the conditions for corporate income tax incentives and loss carryforwards as prescribed by law.

1. Apply a preferential tax rate of 10% for 15 years for:

a) Income of enterprises from implementing new investment projects specified in points a, b, c, d, and đ Clause 2 Article 12 of this Law; income of enterprises specified in point e Clause 2 Article 12 of this Law;

b) Income of enterprises from implementing investment projects specified in points g and h Clause 2 Article 12 of this Law;

c) Income of enterprises from implementing new investment projects in areas specified in point a Clause 3 Article 12 of this Law;

d) Income of enterprises from implementing new investment projects in high-tech zones, advanced technology application agriculture zones, concentrated digital technology zones; new investment projects in economic zones located within tax incentive areas specified in points a and b Clause 3 Article 12 of this Law. In cases where investment projects in economic zones have implementation locations both within and outside tax incentive areas, the determination of tax incentives for such projects shall be regulated by the Government.

2. Apply a preferential tax rate of 10% for:

a) Income of enterprises from activities in industries and professions specified in points k and l Clause 2 Article 12 of this Law in tax incentive areas specified in point b Clause 3 Article 12 of this Law;

b) Income of enterprises from activities in industries and professions specified in points i, r, and s Clause 2 Article 12 of this Law;

c) Income of publishing houses from activities in industries and professions specified in point t Clause 2 Article 12 of this Law;

d) Income of cooperatives and cooperative unions specified in point q Clause 2 Article 12 of this Law not located in areas specified in Clause 3 Article 12 of this Law;

đ) Income of press agencies in industries and professions specified in point u Clause 2 Article 12 of this Law.

3. Apply a preferential tax rate of 15% for income of enterprises from activities in industries and professions specified in point l Clause 2 Article 12 of this Law not located in areas specified in Clause 3 Article 12 of this Law.

4. Apply a preferential tax rate of 17% for 10 years for:

a) New investment projects in industries and professions with preferential treatment specified in points m, n, and o Clause 2 Article 12 of this Law;

b) New investment projects implemented in areas specified in point b Clause 3 Article 12 of this Law;

c) New investment projects in economic zones not located in areas specified in points a and b Clause 3 Article 12 of this Law.

5. Apply a preferential tax rate of 17% for income of enterprises specified in point p Clause 2 Article 12 of this Law.

6. The extension of the duration and application of preferential tax rates are regulated as follows:

a) The Prime Minister decides on extending the application of preferential tax rates for a maximum of 15 additional years for the following projects:

a1) New investment projects specified in points a, b, d, and đ Clause 2 Article 12 of this Law, with a minimum capital investment of 60 trillion VND, significantly impacting the economy and society and requiring special encouragement;

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

- Producing goods with global competitiveness, achieving annual revenue of over 20 trillion VND within five years from the start of project revenue;

- Regularly employing more than 6,000 workers as defined by labor laws;

- Investment projects in economic infrastructure, including: development of water plants, power plants, water supply and drainage systems, roads, railways, airports, seaports, inland ports, energy, clean energy, energy-saving industry, oil refining projects;

b) For new investment projects specified in point h Clause 2 Article 12 of this Law, the Prime Minister decides on applying a reduced tax rate not exceeding 50% of the tax rate stipulated in Clause 1 of this Article; the duration of applying preferential tax rates shall not exceed 1.5 times the duration stipulated in Clause 1 of this Article and can be extended for up to 15 years but not exceeding the project's duration.

7. The duration of applying preferential tax rates for income from new investment projects of enterprises specified in this Article (including projects specified in point g Clause 2 Article 12 of this Law) is calculated from the first year the new investment project generates revenue.

In cases where enterprises obtain certificates for high-tech enterprises, advanced technology application agriculture enterprises, science and technology enterprises, high-tech project certificates, or certificates confirming preferential treatment for production support industry projects after generating revenue, the duration of applying preferential tax rates is calculated from the year the certificate or preferential treatment confirmation was issued.

1. Maximum tax exemption for four years and reduction of fifty percent of the tax payable for up to nine years thereafter for:

a) Income of enterprises as specified in Clause 1, Article 13 of this Law;

b) Income of enterprises as specified at point r, Clause 2, Article 12 of this Law located in areas as specified at points a and b, Clause 3, Article 12 of this Law; in cases not located in such areas, maximum tax exemption for four years and reduction of fifty percent of the tax payable for up to five years thereafter.

2. Maximum tax exemption for two years and reduction of fifty percent of the tax payable for up to four years thereafter for income of enterprises as specified in Clause 4, Article 13 of this Law.

3. For new investment projects as specified at point h, Clause 2, Article 12 of this Law, the Prime Minister decides to extend the period of tax exemption and reduction to a maximum of one and a half times the period of tax exemption and reduction prescribed in Clause 1 of this Article.

4. The period of tax exemption and reduction shall be calculated from the first year of taxable income from the investment project; in cases where there is no taxable income within the first three years, it shall be calculated from the fourth year from the year of first revenue from the project.

In cases where enterprises are granted certificates for high-tech application projects, high-tech enterprises, high-tech agricultural enterprises, science and technology enterprises, and certificates for preferential incentives for production support industry projects after the occurrence of income, the period of tax exemption and reduction shall be calculated from the year of issuance of the certificate or incentive certificate. If there is no income in the year of issuance of the certificate or incentive certificate, the period of tax exemption and reduction shall be calculated from the first year of income; if there is no taxable income within the first three years from the year of issuance of the certificate or incentive certificate, the period of tax exemption and reduction shall be calculated from the fourth year from the year of issuance of the certificate or incentive certificate.

5. Tax incentives for expanded investment projects:

a) Enterprises with ongoing investment projects expanding scale, increasing capacity, updating technology, reducing pollution, or improving the environment in industries, professions, and areas with corporate income tax incentives as stipulated in Article 12 of this Law (hereinafter referred to as expanded investment) shall enjoy tax incentives on additional income generated from expanded investment according to the ongoing project for the remaining period without having to account separately for the additional income from expanded investment with income from the ongoing project;

b) In cases where the ongoing project has exhausted its tax incentive period, additional income from the expanded investment project meeting the criteria specified in Clause 6 of this Article shall be exempted or reduced from tax and shall not enjoy tax rate incentives. The period of tax exemption and reduction for additional income due to expanded investment shall be equal to the period of tax exemption and reduction applied to new investment projects in the same industry, profession, and area with corporate income tax incentives and shall be calculated from the year the expanded investment project completes the registered investment capital.

Enterprises must account separately for additional income from expanded investment to apply for incentives. In cases where separate accounting is not possible, income from expanded investment activities shall be determined based on the ratio between the original value of new fixed assets invested and put into use for production and business operations over the total original value of the enterprise's fixed assets;

c) The tax incentives stipulated in this clause shall not apply to cases of expanded investment through mergers, acquisitions of enterprises, or ongoing investment projects.

6. Expanded investment projects enjoying incentives as specified in point b, Clause 5 of this Article must meet one of the following criteria:

a) The original value of additional fixed assets when the investment project completes the disbursement of registered expanded investment capital reaches the minimum level set by the Government corresponding to the cases of expanded investment projects in industries and professions with corporate income tax incentives, and expanded investment projects implemented in areas with corporate income tax incentives;

b) The proportion of the original value of additional fixed assets when the investment project completes the disbursement of registered expanded investment capital increases to a minimum of twenty percent compared to the total original value of fixed assets before the start of expanded investment;

c) The additional designed capacity when the investment project completes the disbursement of registered expanded investment capital increases to a minimum of twenty percent compared to the designed capacity before the start of expanded investment.

1. Enterprises engaged in production, construction, transportation that employ many female workers shall be entitled to a reduction in corporate income tax equivalent to the additional costs for female labor.

2. Enterprises employing many workers from ethnic minority groups shall be entitled to a reduction in corporate income tax equivalent to the additional costs for ethnic minority labor.

3. Enterprises implementing technology transfer in priority areas for organizations and individuals in economically disadvantaged areas, public institutions providing public services in economically disadvantaged areas shall be entitled to a 50% reduction in corporate income tax on the portion of income derived from technology transfer and provision of public services in economically disadvantaged areas.

4. New enterprises established from individual businesses under Article 10, Clause 2 of this Law shall be exempted from corporate income tax for two consecutive years from the date they start generating taxable income.

5. Public scientific and technological organizations, public higher education institutions operating without profit objectives shall be exempted from tax according to the provisions of the Government.

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

Article 16. Carryforward of Losses

1. Enterprises with losses may carry forward such losses to the next year; these losses shall be deducted from taxable income. The period for carrying forward losses shall not exceed five consecutive years, starting from the year following the year in which the losses occurred.

2. Enterprises with losses arising from the transfer of mineral exploration and exploitation projects; the transfer of rights to participate in mineral exploration, exploitation, and processing projects; the transfer of rights to explore, exploit, and process minerals may carry forward such losses to the next year against the taxable income from those activities. The period for carrying forward losses shall be governed by Clause 1 of this Article.

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

Article 17. Establishment of Science and Technology Development Fund

1. Enterprises, organizations, and public institutions established in accordance with Vietnamese law may allocate up to 20% of their annual taxable income to establish a Science and Technology Development Fund.

2. Within five years from the date of establishment as prescribed in Clause 1 of this Article, if the Science and Technology Development Fund is not utilized or is not fully utilized at 70%, or is used for improper purposes, then the enterprise, organization, or public institution must pay to the state budget the corporate income tax calculated on the portion of income allocated to the fund that was not utilized or used for improper purposes, along with the interest generated from such tax.

The corporate income tax rate used to calculate the amount of tax to be recovered is the rate applicable to the enterprise, organization, or public institution during the period of establishing the fund.

The interest rate applied to the portion of the fund not fully utilized is the interest rate of government bonds with a term of five years or ten years (in case there is no five-year term bond) issued closest to the recovery date, and the interest calculation period is two years.

The interest rate applied to the portion of the fund used for improper purposes is the late payment interest rate stipulated by the Tax Administration Law, and the interest calculation period is the time from the establishment of the fund until its recovery.

3. Enterprises, organizations, and public institutions shall not include expenditures from the Science and Technology Development Fund in deductible expenses when determining taxable income for the tax period.

4. The Science and Technology Development Fund shall be used in accordance with laws on science, technology, and innovation.

5. In the event of changes due to mergers, consolidations, divisions, spin-offs, ownership transfers, or business form conversions while an enterprise is in operation, the newly established enterprise, or the enterprise receiving the merger, consolidation, division, spin-off, or ownership conversion shall inherit and be responsible for managing and utilizing the Science and Technology Development Fund of the enterprise prior to the merger, consolidation, division, spin-off, or business form conversion.

Article 18. Conditions for Applying Tax Incentives

1. The corporate income tax incentives stipulated in Articles 13, 14, and 15 of this Law shall apply to enterprises that maintain accounting records, invoices, and documents and pay taxes according to the declaration method.

Corporate income tax incentives under the new investment project category (including projects under point g, Clause 2, Article 12 of this Law) stipulated in Articles 13 and 14 of this Law shall not apply to cases of merger, consolidation, division, spin-off, change of ownership, conversion of enterprise form, and other cases prescribed by the Government.

2. Enterprises must separately account for income from production and business activities eligible for tax incentives stipulated in Articles 4, 13, 14, and 15 of this Law with income from production and business activities not eligible for tax incentives; if separate accounting is not possible, the income from production and business activities eligible for tax incentives shall be determined based on the ratio between revenue or costs of the production and business activities eligible for tax incentives over the total revenue or total costs of the enterprise.

3. The tax rates of 15% and 17% stipulated in Clause 2 and Clause 3, Article 10 of this Law and the provisions on tax incentives stipulated in Articles 4, 13, 14, and 15 of this Law shall not apply to:

a) Income from capital transfer, capital contribution rights transfer; income from real estate transfer (except income from social housing construction projects under point s, Clause 2, Article 12 of this Law); income from investment project transfer (excluding mineral processing project transfers), investment project participation right transfer, mineral exploration, exploitation, and processing rights transfer; income from production and business activities outside Vietnam;

b) Income from oil and gas exploration, extraction, and rare resource exploitation activities and income from mineral exploration and extraction activities;

c) Income from online electronic game production and business activities; income from goods and services subject to special consumption tax as provided for in the Special Consumption Tax Law, except for automobile, aircraft, helicopter, roller coaster, yacht, and oil refining production and assembly projects;

d) Special cases as prescribed by the Government.

4. The tax rates of 15% and 17% stipulated in Clause 2 and Clause 3, Article 10 of this Law shall not apply to enterprises that are subsidiary companies or associated companies where the associated company does not meet the conditions for applying the tax rate prescribed in Clause 2 and Clause 3, Article 10 of this Law.

5. If an enterprise fails to meet the conditions for tax incentives, the competent authority shall recover taxes and impose penalties according to the law.

6. The Government shall provide detailed regulations for Clause 5 of this Article. The Ministry of Finance shall prescribe procedures and documents for enjoying tax incentives stipulated in Articles 4, 13, 14, and 15 of this Law.

Chapter IV

IMPLEMENTING PROVISIONS

Article 19. Effective Date

1. This Law takes effect from October 1, 2025, and applies from the 2025 corporate income tax period.

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

3. In cases where economic development organizations and the United Nations have more favorable provisions and guidelines regarding taxation rights for countries of origin, including Vietnam, the Government shall specify detailed regulations for implementation.

Article 20. Transitional Provisions

1. Enterprises with investment projects eligible for corporate income tax incentives as prescribed by the corporate income tax laws at the time of permit issuance or investment certificate issuance or permission to invest according to the investment laws, if the corporate income tax laws are amended and supplemented and the enterprise meets the conditions for tax incentives under the newly amended laws, the enterprise may choose to enjoy tax rate incentives and tax exemption and reduction periods according to the laws at the time of permit issuance, investment certificate issuance, or permission to invest or according to the newly amended laws for the remaining period.

2. In cases where enterprises with investment projects are not eligible for incentives under the previous tax laws before the effective date of this Law but are eligible under this Law, they shall be entitled to apply the incentives under this Law for the remaining period starting from the 2025 tax period.

This Law was passed by the National Assembly of the Socialist Republic of Vietnam, Session 9, Term XV, on June 14, 2025.