Value Added Tax (VAT)
New conditions for input VAT credit under Decree No. 144/2026/ND-CP
Decree No. 144/2026/ND-CP, effective from 20 June 2026, amends Point (g), Clause 2, Article 26 of Decree No. 181/2025/ND-CP regarding the documentary requirements for claiming input VAT credits in respect of certain deferred and instalment purchases.
The amended provision clarifies the circumstances under which taxpayers may provisionally claim input VAT credits before the contractual payment due date, the requirement to reverse such credits where non-cash payment evidence is not available by the agreed payment date, and the subsequent re-claim of the input VAT credit once valid non-cash payment evidence is obtained.
The amended provision reads as follows:
"(g) For purchases of goods or services under deferred payment or instalment arrangements with a purchase value of VND 5 million or more, a business establishment shall rely on a written contract for the purchase of goods or services, a value-added tax invoice, and non-cash payment evidence for such deferred payment or instalment purchases as the basis for claiming input value-added tax credits.
Where non-cash payment evidence is not yet available because the payment due date under the contract or contract appendix has not yet occurred, the business establishment shall still be entitled to claim input value-added tax credits.
By the payment due date under the contract or contract appendix, if the business establishment does not possess non-cash payment evidence, it shall declare and adjust downward the amount of deductible input value-added tax corresponding to the value of goods or services for which non-cash payment evidence is unavailable in the tax period in which the payment obligation arises under the contract or contract appendix.
Where, after making such adjustment, the business establishment subsequently obtains non-cash payment evidence, it shall be entitled to declare and claim input value-added tax credits corresponding to the value of goods or services supported by such non-cash payment evidence in the tax period in which such non-cash payment evidence is obtained."
Corporate Income Tax (CIT)
Corporate income tax incentive under Government Decree No. 20/2026/ND-CP
Under Decree No. 20/2026/ND-CP, foreign-invested enterprises may be eligible for a three-year Corporate Income Tax ("CIT") exemption, provided that they are established in accordance with Vietnamese law, satisfy the criteria applicable to small and medium-sized enterprises ("SMEs"), and meet the prescribed conditions for tax incentives.
The tax authority has further clarified the application of this incentive in Official Letter No. 3896/CT-CS dated 11 June 2026, as follows:
Foreign-invested enterprises established and registered in accordance with Vietnamese law, having been granted an Enterprise Registration Certificate for the first time, satisfying the criteria for SMEs under the Law on Support for Small and Medium-sized Enterprises and Decree No. 80/2021/ND-CP, and not falling within the ineligible cases prescribed in Point (b), Clause 3, Article 7 of Decree No. 20/2026/ND-CP, shall be entitled to a CIT exemption for three (03) years from the date of issuance of their first Enterprise Registration Certificate.
The CIT exemption does not apply to the categories of income specified in Clause 3, Article 18 of the Law on Corporate Income Tax No. 67/2025/QH15.
In Official Letter No. 3897/CT-CS, the Tax Department requested the Ho Chi Minh City Tax Department to cease implementing the guidance provided in Official Letter No. 2169/TPHCM-QLDN3 dated 9 March 2026, under which enterprises were considered ineligible for the three-year CIT exemption, and to instruct taxpayers to implement the guidance set out in Official Letter No. 3896/CT-CS.
(Official Letter No. 1088/CT-CS dated 8 May 2025 issued by the Tax Department)
Personal Income Tax (PIT)
Tax authority issues guidance on filing PIT returns for employment income under Resolution No. 66.16/2026/NQ-CP
The Tax Department has issued guidance on the filing of Personal Income Tax ("PIT") returns in respect of employment income pursuant to Resolution No. 66.16/2026/NQ-CP.
Specifically, taxpayers under the management of the tax authority are required to file quarterly PIT returns using Forms No. 02/KK-TNCN and 05/KK-TNCN issued together with Circular No. 80/2021/TT-BTC, starting from the Q2/2026 tax period.
For taxpayers whose April 2026 monthly PIT returns have already been accepted by the tax authority, the guidance provides as follows:
- When filing the Q2/2026 PIT return, taxpayers shall only include tax liabilities arising in May and June 2026. Tax liabilities already declared in the April 2026 monthly return must not be included in the Q2/2026 return in order to avoid duplicate tax reporting.
- Where taxpayers identify any errors in the April 2026 monthly PIT return, they shall submit an amended April 2026 PIT return in accordance with the prevailing regulations.
- PIT liabilities arising from the April 2026 monthly PIT return (if any) may be paid by the filing deadline applicable to the Q2/2026 PIT return, i.e. 31 July 2026.
(Official Letter No. 4021/CT-NVT dated 16 June 2026)
Foreign Contractor Tax (FCT)
Guidance on determining taxable revenue for Foreign Contractor Tax purposes
The Ninh Binh Provincial Tax Department has issued guidance on determining taxable revenue for Foreign Contractor Tax ("FCT") purposes under Official Letter No. 7061/NBI-QLDN2 dated 25 May 2026.
Pursuant to the prevailing regulations, taxable revenue for Corporate Income Tax applicable to foreign contractors and foreign subcontractors under Clause 3, Article 7 of Circular No. 20/2026/TT-BTC dated 12 March 2026 shall be determined on the basis of gross revenue, inclusive of VAT and CIT, received by the foreign contractor, including expenses paid on behalf of the foreign contractor or foreign subcontractor by the Vietnamese party (if any), in accordance with Clause 1, Article 8 of Government Decree No. 320/2025/ND-CP dated 15 December 2025.
For foreign contractor agreements applying the direct method (i.e. taxation based on a prescribed percentage of revenue), the Vietnamese party shall declare and pay CIT on behalf of the foreign contractor based on the time the CIT liability arises. The applicable legal document shall be determined according to its effective date in accordance with Article 58 of the Law on Promulgation of Legislative Documents No. 64/2025/QH15.
(Official Letter No. 7061/NBI-QLDN2 dated 25 May 2026)
