Decree 320/2025/ND-CP on Law on Corporate Income Tax (CIT)
On 15 December 2025, the Government promulgated Decree 320/2025/ND-CP (“Decree 320”), providing detailed regulations on a number of articles of, and measures for the implementation and guidance of, the Law on Corporate Income Tax (“CIT”). Accordingly, Decree 320 introduces a number of notable updates, including the following.
Key takeaways:
- Clarification of taxpayers and the scope of application of CIT
- Expansion of the cases constituting a PE for foreign enterprises
- Changes in the classification of income from business activities and other income
- Further clarification of provisions on types of tax-exempt income
- Clarification of rules on offsetting taxable income within a tax period and the application of loss carryforward provisions
- Changes to deductible expenses
- Additions and amendments to groups of nondeductible expenses
- Additions and amendments to regulations on the tax calculation method based on a percentage of taxable revenue arising in Vietnam for foreign enterprises with or without a permanent establishment in Vietnam
- CIT incentives
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Please refer to the full updates in the Download section below.
Contacts
Da Nguyen Partner, Tax
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On 10 December 2025, the National Assembly officially passed the Law on Personal Income Tax (“PIT”) No. 109/2025/QH15, replacing the Law on PIT No. 04/2007/QH12 passed in 2007. The new Law introduces amendments to a number of regulations concerning taxpayers, taxable income, tax-exempt income, tax reductions, and the basis for PIT calculation.
Decree 320/2025/ND-CP on CIT
On 15 December 2025, the Government promulgated Decree 320/2025/ND-CP (“Decree 320”), providing detailed regulations on a number of articles of, and measures for the implementation and guidance of, the Law on Corporate Income Tax (“CIT”). Accordingly, Decree 320 introduces a number of notable updates, including the following.
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