

SUMMARY OF KEY POINTS OF CORPORATE INCOME TAX LAW 2025 COMPARED TO THE 2008 LAW
(AMENDED, SUPPLEMENTED)
The Corporate Income Tax Law No. 67/2025/QH15 (hereinafter referred to as the CIT Law) takes effect from October 1, 2025, and applies to the 2025 tax year. This is an important legal document, with many practical adjustments, directly affecting tax declaration, calculation, payment obligations, and legitimate rights of the business community.
To ensure the highest level of client support, IFRS has undertaken timely research, synthesis, and analysis of the new regulations, thereby delivering critical insights that enable businesses to proactively secure full compliance with the law.

1. Differentiating income from real estate transfer according to the business line of the enterprise.
2. All income originating in Vietnam of foreign enterprises without a head office address in Vietnam is subject to CIT.
3. Legalizing income from business cooperation contracts (BCC) as “other income” subject to CIT.
4. Provisions accrued into deductible expenses but not used or not fully used without adjustment to reduce deductible expenses shall be considered taxable income (instead of merely excluding such provisions when determining CIT-deductible expenses).
5. Addition of 06 tax-exempt incomes, including differences from asset revaluation upon equitization of enterprises wholly owned by the State.

6. Enterprises may choose business activities with taxable income to offset losses (except income from real estate transfer, investment project transfer, or transfer of the right to participate in investment projects).
7. Only listed deductible expenses are allowed when determining taxable income (instead of all expenses meeting general conditions as previously regulated).
8. CIT rate of 15% applies to enterprises with annual total revenue not exceeding VND 3 billion; 17% applies to enterprises with revenue over VND 3 billion up to VND 50 billion (excluding income from capital transfer, real estate transfer, investment project transfer, etc.).
9. Enterprises with annual revenue not exceeding VND 3 billion that record revenue but cannot determine expenses or income are subject to CIT calculation by a deemed percentage method.
10. Addition of 07 industries eligible for preferential tax rates and tax exemption/reduction periods.
11. CIT exemption/reduction applied from the 4th year if the enterprise has revenue in the first 3 years but no taxable income.
12. CIT incentives for expansion investment if capacity or original cost of fixed assets increases by at least 20% compared to before the investment.
13. Narrowing the scope of loss carryforward: no longer applied to real estate transfer activities and investment projects (except mining activities).

Detailed information is available in the summary below for your reference:


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