New points of the Corporate Income Tax Law 2025

The Law on Corporate Income Tax (CIT) 2025 was passed by the 15th National Assembly and will take effect from October 1, 2025. Compared to the previous Law, this new Law has adjusted a number of regulations and added many notable new points, in line with the motto of creating, accompanying and supporting businesses to overcome difficulties and develop.

Expanding the scope and adding more taxable incomes

Accordingly, the 2025 Law on Corporate Income Tax (CIT) imposes tax on all income in Vietnam of foreign enterprises regardless of their business location. Specifically, at Point d, Clause 2, Article 2 of the 2025 Law on Corporate Income Tax, the subjects subject to corporate income tax are expanded to include foreign enterprises without a permanent establishment in Vietnam, including enterprises engaged in e-commerce and digital platform-based businesses, which must pay tax on taxable income arising in Vietnam.

In addition, Clause 3, Article 3 of the Law on Corporate Income Tax 2025 supplements the principle of determining taxable income of foreign enterprises in Vietnam as income received originating from Vietnam, regardless of the location of business.

In addition, in Article 3, the Law has added many incomes subject to corporate income tax, including: The difference between fines, compensation for breach of economic contracts or rewards for good performance of contractual commitments; donations and gifts in cash or in kind received; the difference due to revaluation of assets according to the provisions of law for capital contribution, transfer when merging, consolidating, dividing, separating, converting ownership, converting business types; income from business cooperation contracts; income from production and business activities abroad; income of public service units for public asset leasing activities and other incomes, except for tax-exempt incomes.

Enterprises participating in green and circular production will receive income tax reduction. Photo: Nguyen Hai

Incentives to reduce tax exemption period for new technology products, green production and circular economy

According to Clause 4, Article 4 of the Law on Corporate Income Tax 2025: Income from the implementation of scientific research contracts, technology development and innovation, digital transformation; income from the sale of products made from new technology applied for the first time in Vietnam; income from the sale of experimentally produced products during the experimental production period including controlled experimental production according to the provisions of law. Income in this clause is exempt from tax for a maximum of 03 years.

Previously, the above income was tax-free for a maximum of 05 years.

Amendments to industries and occupations with preferential corporate income tax

Specifically, Article 12 and Article 13 of the 2025 Law on Corporate Income Tax have adjusted the list of industries and occupations enjoying corporate income tax incentives with many notable new points, in which a number of prominent fields are included in the list of industries and occupations enjoying corporate income tax incentives, including: Projects subject to special investment incentives and support as prescribed in Clause 2, Article 20 of the Investment Law. The Government shall specify in detail the time for disbursement of total registered investment capital of projects specified in this point; investment in technical facilities to support small and medium-sized enterprises, small and medium-sized enterprise incubators; investment in shared office space to support small and medium-sized enterprises to start up and innovate according to the provisions of the Law on Support for Small and Medium Enterprises; supplementing preferential industries: Digital technology services, network information security, semiconductor chips, data centers and artificial intelligence.

The law also removes some industries and professions that enjoy incentives, such as production projects with a minimum investment capital of VND6,000 billion; and investment projects in industrial parks.

Delegates visit technology booths of 2025 technology enterprises. Photo: Nguyen Hai

Expanding the scope of corporate income tax exemption

According to Clause 10, Article 4, Law on Corporate Income Tax 2025, the subjects exempted from corporate income tax are expanded to: Income from the transfer of emission reduction certificates, the first transfer of carbon credits after issuance by enterprises granted emission reduction certificates, carbon credits; income from green bond interest; income from the first transfer of green bonds after issuance.

Add some deductible expenses when determining taxable income

In Article 9 of the Law on Corporate Income Tax 2025, additional deductible expenses are added when determining taxable income of corporate income, specifically as follows:

Actual expenses for seconded persons participating in the administration, management and control of specially controlled credit institutions and commercial banks subject to compulsory transfer under the provisions of the Law on Credit Institutions;

Costs of participating in trade promotion and technology innovation fairs will be deducted from taxable expenses of enterprises. Photo: Nguyen Hai

Some expenses for production and business of enterprises but not corresponding to revenue generated during the period according to Government regulations;

Some expenses support the construction of public works, while also serving the production and business activities of enterprises;

Costs related to reducing greenhouse gas emissions to achieve carbon neutrality and net zero, reducing environmental pollution, and related to the production and business activities of enterprises; some contributions to funds established by Government decision.

Amending corporate income tax rates

In addition to the general corporate income tax rate of 20% under the old regulations, Article 10 of the 2025 Law on Corporate Income Tax stipulates additional tax rates based on revenue: A tax rate of 15% applies to enterprises with total annual revenue of no more than VND 3 billion; a tax rate of 17% applies to enterprises with total annual revenue from over VND 3 billion to no more than VND 50 billion.

The Law also stipulates corporate income tax rates for a number of specific business sectors, including: For oil and gas exploration and exploitation activities from 25% to 50%...

Source: https://baonghean.vn/diem-moi-cua-luat-thue-thu-nhap-doanh-nghiep-nam-2025-10309706.html