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Vietnam: Guidance on new corporate income tax law

Effective December 15, 2025

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December 18, 2025

The government on December 15, 2025, issued Decree 320/2025/ND-CP, which provides detailed guidance on the new law on corporate income tax (CIT).

Decree 320 introduces a number of significant changes to the corporate tax framework, including but not limited to:

  • The introduction of a deemed CIT rate of 2% on gross sale proceeds applicable to capital transfers (direct or indirect) by foreign enterprises, effective from December 15, 2025
  • Various new rules on expense deductibility, tax loss carry-forward, and the CIT incentive regime

Decree 320 takes effect from December15, 2025 and generally applies to the 2025 fiscal year. The decree also contains transitional provisions allowing taxpayers to elect to apply certain provisions for the entire 2025 fiscal year, or from October 1, 2025 (i.e., the effective date of the Law on CIT), or from December 15, 2025, whichever is more beneficial.

Read a December 2025 report prepared by the KPMG member firm in Vietnam

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