Investment incentives and high-tech agriculture: corporate income tax exemptions and preferential rates for farming, processing and inputs, the end of the high-tech agricultural enterprise certificate and the new high-tech categories, high-tech agricultural zones, land rent relief and cash support under Decree No. 57/2018/ND-CP, VAT on produce and inputs, import duty, credit and agricultural insurance, with a worked example

How agricultural incentives are built

Agriculture is one of the sectors the Law on Investment 2025 prioritises, and Article 15 of Law No. 143/2025/QH15 offers the same four forms of incentive to an agricultural project as to any other: corporate income tax relief, import duty exemption, relief from land use levy, land rent and land use tax, and accelerated depreciation or higher deductible expenses (Investment incentives; FAQ 31). What an agricultural project actually receives, however, is decided by several other instruments, each with its own lists and conditions, and the analysis has to be done instrument by instrument.

Six layers matter. The Corporate Income Tax Law, Law No. 67/2025/QH15, in force from the 2025 tax period and detailed by Decree No. 320/2025/ND-CP as amended, gives agriculture its most valuable incentive: exempt or low-taxed income by reference to the activity and the location. The Law on High Technology, Law No. 133/2025/QH15, in force from 1 July 2026, with Decree No. 260/2026/ND-CP and Decree No. 263/2026/ND-CP, governs high-tech status and high-tech agricultural zones. The land rules, Article 157 of Land Law No. 31/2024/QH15, Decree No. 103/2024/ND-CP and Decree No. 230/2025/ND-CP, grant rent relief, which for agricultural projects Article 5(2) of Decree No. 230/2025/ND-CP routes through the Government's decree on encouraging enterprises to invest in agriculture, Decree No. 57/2018/ND-CP, which also provides cash support. The VAT Law, Law No. 48/2024/QH15 as amended by Law No. 149/2025/QH15, takes most farm produce and many inputs outside VAT or at 5%, which is a cost rule more than an incentive. The Law on Export and Import Duties, Law No. 107/2016/QH13, exempts equipment for incentivised projects. And sector support decrees on credit (Decree No. 55/2015/ND-CP as amended), insurance (Decree No. 58/2018/ND-CP as amended) and linkages (Decree No. 98/2018/ND-CP) add financing and risk-sharing measures.

All of these apply equally to foreign-invested and Vietnamese enterprises; a foreign-invested project usually has its incentives recorded in its Investment Registration Certificate, while CIT incentives are self-assessed in the tax return in either case (FAQ 40). Where a project qualifies for more than one incentive level for the same income, Article 12(1) of the CIT Law lets the enterprise choose the most beneficial.

Corporate income tax: exempt agricultural income

Article 4 of Law No. 67/2025/QH15 lists income that is exempt from CIT altogether, not merely taxed at a lower rate, and agriculture features prominently. Under Article 4(1), the following are exempt: income from fishing activities; an enterprise's income from the production of products from planted trees, planted forests, livestock production and aquaculture, and from the processing of agricultural and aquatic products (including where the enterprise buys the agricultural or aquatic products it processes), in areas with extremely difficult socio-economic conditions; and the income of cooperatives and unions of cooperatives from the same activities and from salt production, wherever they are. Article 4(2) exempts the income of agricultural, forestry, fisheries and salt cooperatives in difficult or extremely difficult areas, and Article 4(3) exempts income from technical services directly for agriculture, whoever provides them and wherever.

Three points of application matter. The location test turns on where the income-producing activity takes place, against the areas the Government lists for CIT purposes under Article 12(3); after the 2025 abolition of districts, confirm on the current list that the farm's or plant's commune is covered. Processing income qualifies only if the processing meets the conditions the Government sets under Articles 4 and 12(2)(l). And exempt income must be accounted for separately under Article 18(2), with common costs allocated by revenue or expense ratios where separation is impossible.

Corporate income tax: preferential rates and holidays

Outside the exemption, Articles 12 to 14 of the CIT Law set a ladder of rates for agricultural activities, which the table below summarises. The key distinction is between rates that apply for the life of the activity, with no holiday, and rates that apply to a new investment project for a fixed period, with an exemption and reduction period.

For the life of the activity: income from planted products, livestock, aquaculture and processing (Article 12(2)(l)) and from forest farming (Article 12(2)(k)) is taxed at 10% in areas with difficult socio-economic conditions (Article 13(2)(a)) and at 15% outside the incentivised areas (Article 13(3)), against the standard rate of 20%. Income from planting, tending and protecting forests, from producing, propagating and hybridising plant varieties and animal breeds, from post-harvest preservation of agricultural products and the preservation of agricultural and aquatic products and food, and from salt production other than by cooperatives (Article 12(2)(i)) is taxed at 10% wherever the activity is located (Article 13(2)(b)). Agricultural, forestry, fisheries and salt cooperatives outside the incentivised areas also pay 10% (Article 13(2)(d)).

For new projects, with holidays: a new project in an area with extremely difficult conditions, whatever its sector, pays 10% for 15 years with four years' exemption and a 50% reduction for the following nine years (Articles 13(1)(c) and 14(1)); a new project in a hi-tech park or a high-tech agricultural zone receives the same package (Article 13(1)(d)); and a new project manufacturing machinery and equipment for agricultural, forestry, fisheries and salt production, irrigation equipment, or cattle, poultry and aquatic feed (Article 12(2)(m)) pays 17% for 10 years with two years' exemption and four years at 50% (Articles 13(4)(a) and 14(2)), as does any new project in an area with difficult conditions (Article 13(4)(b)). The exemption period runs from the first year of taxable income, or from the fourth year of revenue if there is no taxable income in the first three years (Article 14(4)); the rate period runs from the first year of revenue (Article 13(7)). Qualifying expansion projects may share the original project's incentives for the remaining period or, if those have expired, receive a fresh exemption and reduction (Article 14(5) and (6)) (FAQ 33).

Some income is excluded whatever the activity. Under Article 18(3), no incentive and neither of the small-enterprise rates applies to gains on the transfer of capital, real estate or projects, to income earned outside Vietnam, or to income from producing goods subject to special consumption tax, which matters to processors of beer, tobacco and, once the tax extends to sugary drinks on 1 January 2027, some beverage makers. Incentives also require proper accounting and invoicing and payment of tax by declaration (Article 18(1)), and CIT incentives for new projects are not available where the project results from a merger, division or transfer of an existing project (Article 18(1)). The groups of at least EUR 750 million consolidated revenue that fall within the global minimum tax may find low agricultural rates topped up to 15% (FAQ 36).

High-tech agriculture after the 2025 Law on High Technology

Until 30 June 2026 Vietnam had a distinct status of high-tech agricultural enterprise (doanh nghiệp nông nghiệp ứng dụng công nghệ cao), certified by the agriculture ministry under Law No. 21/2008/QH12 on High Technology and the criteria in Decision No. 19/2018/QD-TTg. The certificate carried the top-tier CIT package, and Article 12(2)(e) of the 2025 CIT Law still listed such enterprises alongside high-tech enterprises. Law No. 133/2025/QH15 on High Technology, passed on 10 December 2025 and in force from 1 July 2026, replaced the 2008 law and did not continue that category. Its Article 25(7) amended the CIT Law to remove the words "hi-tech agricultural enterprises" and to add a transitional rule under which enterprises holding certificates issued under the 2008 law keep their incentives until the certificate expires, and Article 27 keeps certificates issued under the 2008 law valid until their stated expiry. An agribusiness holding a certificate should therefore diarise its expiry date, because no like-for-like renewal exists.

A high-tech agribusiness now qualifies, if at all, under the general categories of the new law, which depend on whether its technologies and products appear on the Prime Minister's lists of high technologies prioritised for development and high-tech products encouraged for development, updated in 2026 (including by Decision No. 23/2026/QD-TTg of 15 May 2026). A high-tech product manufacturing enterprise receives 17% for 10 years with two years' exemption and four years at 50%; a Group 2 high-tech enterprise, which must also own or lawfully use the technology and meet thresholds for revenue, research and development spending in Vietnam and research staff, receives 10% for 15 years with four years' exemption and nine years at 50%; and a Group 1 high-tech enterprise, which in addition conducts research and development or meets a localisation threshold, receives 10% for 25 years with the same holiday. A strategic technology enterprise receives the Group 1 package but must, save in special cases decided by the Prime Minister, be at least 51% owned by domestic investors. Decree No. 260/2026/ND-CP of 30 June 2026 sets the detailed criteria; the Ministry of Science and Technology confirms Group 1 enterprises, Group 2 enterprises with total capital of VND 6,000 billion or more and strategic technology enterprises, and the provincial Departments of Science and Technology confirm high-tech product manufacturers and smaller Group 2 enterprises. A Ministry of Finance draft amending Decree No. 320/2025/ND-CP to implement these rates was reported to the Prime Minister on 31 July 2026.

Separately, Article 12(2)(a) of the CIT Law continues to treat the application of high technologies on the prioritised list as an incentivised sector, so a new project applying a listed technology may claim 10% for 15 years with the 4 plus 9 holiday (Article 13(1)(a)). Whether a greenhouse, tissue-culture or precision-livestock system is a listed technology is a question of fact, and the investor should obtain the confirmation the new procedures provide, or keep a technical file supporting its assessment.

High-tech agricultural zones (khu nông nghiệp ứng dụng công nghệ cao) continue. Article 24 of Law No. 133/2025/QH15 defines them as places for applied research, trial production, testing, demonstration, incubation and technology transfer in agriculture, allows regulatory sandboxes in them, and gives the provincial People's Committee the power to decide their establishment, expansion and adjustment; zones established before 1 July 2026 continue, and applications to establish a zone received before that date are processed under the 2008 law. Decree No. 263/2026/ND-CP, in force from 1 July 2026, sets six establishment conditions (consistency with regional or provincial planning and an allocated land use quota; transport, power, water and telecommunications connections; adequate and unfragmented land; digital and laboratory facilities; and feasible financing and staffing plans) and, as reported, support for projects in the zones that includes priority for State science and technology tasks, up to 100% of certain training and domestic IP registration costs and interest support of 70% of the loan rate, capped at 8% a year, for equipment and production lines used to commercialise high technology. For CIT, a new project in a high-tech agricultural zone receives 10% for 15 years with four years' exemption and nine years at 50% under Article 13(1)(d) of the CIT Law, a location ground that, unlike an industrial park location, survived the 2025 reform (FAQ 34).

Land rent relief and cash support under Decree No. 57/2018/ND-CP

Article 157(1)(a) of the Land Law allows land use levy and land rent to be exempted or reduced for land used for production and business in incentivised sectors or locations, and Article 5(2) of Decree No. 230/2025/ND-CP of 19 August 2025 provides that exemptions and reductions for enterprises' agricultural and rural investment projects follow the Government's policy on encouraging enterprises to invest in agriculture and rural areas, which is Decree No. 57/2018/ND-CP of 17 April 2018. That decree remained in force at 16 October 2026. It classifies agricultural projects in the business lines listed in its appendix into three tiers by location: an especially incentivised agricultural investment project in an area with extremely difficult conditions, an incentivised project in an area with difficult conditions, and an encouraged project elsewhere in rural areas.

The land rent consequences under Article 6 are the most valuable part. An especially incentivised project is exempt from rent on State land and water surface from the date of the lease, for the whole term; an incentivised project is exempt for the first 15 years and pays 50% for the following 7 years; an encouraged project is exempt for the first 11 years and pays 50% for the following 5 years; and a new small or medium-sized agricultural enterprise is exempt for 5 years and pays 50% for the next 10. Land used for worker housing and certain non-farm facilities of qualifying projects is also exempt. Article 7 adds support for land consolidation: the State pays an especially incentivised project 20% of the rent it pays to households and individuals for the first 5 years, and supports a project receiving land use rights as a capital contribution for a raw-material area at VND 50 million per hectare, up to VND 10 billion per project. Under Resolution No. 254/2025/QH15 a full-term exemption needs no separate application, but multi-year exemptions should be claimed with the lease file so that they are recorded (Land rent, land prices and Resolution 254). Decree No. 230/2025/ND-CP adds land rent reductions for agricultural, forestry and aquaculture enterprises that employ ethnic minority workers (50% where they make up 30% to under 50% of the workforce, exemption at 50% or more) and relief for lessees whose crops or stock are damaged by natural disaster or fire.

The decree also offers cash support, paid after investment from provincial and central budgets: interest-rate support on commercial loans for up to 8 years for especially incentivised projects, 6 for incentivised and 5 for encouraged projects, on loans of up to 70% of project investment (Article 8); grants for research, technology purchase, tissue-culture facilities and the production of varieties and breeds (Article 9); training and market-development support (Article 10); support for processing plants, including 60% of the cost of the project's infrastructure and equipment up to VND 15 billion, subject to output-value conditions (Article 11); support for concentrated dairy and beef cattle farms of VND 5 billion per project (Article 12); and support for rural infrastructure, including VND 200 million per hectare for aquaculture projects of at least 5 hectares, up to VND 10 billion (Article 13). The support is granted by the provincial People's Committee after appraisal by the provincial Department of Finance and is paid 70% on acceptance of the works and 30% after operations start. The decree applies to enterprises established under the Law on Enterprises, a definition that does not exclude foreign-invested companies, but the money comes from limited provincial budgets, so a written commitment should be obtained before investing. And a replacement decree is being prepared: at a meeting on 31 March 2026 the Deputy Prime Minister asked the Ministry of Finance, with MAE, to complete a draft that would support up to 30% of investment costs, cap support for raw-material areas at VND 10 billion per project and lower the investment threshold for supported processing projects from VND 60 billion to VND 45 billion.

VAT on agricultural produce and inputs

VAT shapes agricultural margins more than any other tax, and its rules changed twice in six months (VAT and e-invoicing). Under Article 5 of Law No. 48/2024/QH15, as amended by Law No. 149/2025/QH15 from 1 January 2026, the following are not subject to VAT: crop, planted forest, livestock, aquaculture and fishery products that have not been processed into other products or have undergone only ordinary preliminary processing, when sold by the organisation or individual that produced or caught them, and at import (Article 5(1)); livestock breeds and plant propagating materials (Article 5(2)); animal feed and aquatic feed (Article 5(3)); irrigation and drainage, ploughing and harrowing, dredging of in-field canals and harvesting services for agriculture (Article 5(6)); and crop, livestock and other agricultural insurance (Article 5(8)).

At the commercial stage, Law No. 149/2025/QH15 restored, from 1 January 2026, the rule that an enterprise, cooperative or union of cooperatives that buys unprocessed products and sells them to another enterprise, cooperative or union of cooperatives is not required to declare and pay VAT but may deduct its input VAT; between 1 July and 31 December 2025 such sales had borne 5%. Sales of unprocessed products by a trading enterprise to households, individual businesses and consumers bear 5% (Article 9(2)(d)). Processed agricultural products, timber and bamboo shoots bear the standard rate of 10%, reduced to 8% until 31 December 2026 for goods that are not excluded. Inputs bear 5% where listed: fertiliser, ores for producing fertiliser, plant protection products and livestock growth stimulants (Article 9(2)(b)); dredging and earthworks for agricultural canals and ponds, crop cultivation, care and pest control, and preliminary processing and preservation of agricultural products (Article 9(2)(c)); and specialised machinery and equipment for agricultural production as the Government defines it, and offshore fishing vessels (Article 9(2)(g)).

The consequence for a grower is that a sale of its own unprocessed produce is outside VAT, so the input VAT on its fertiliser, greenhouse structures, equipment and services attributable to that produce is in principle not creditable and becomes a cost; input VAT attributable to taxable or exported supplies is creditable, with apportionment by revenue where inputs are shared. A business supplying only 5%-rated goods may claim a refund once unrecovered input VAT reaches VND 300 million after 12 months or four quarters. Law No. 149/2025/QH15 also removed, from 1 January 2026, the condition in the 2024 law that the seller must have declared and paid the VAT on the invoices used for a refund claim, and raised the annual revenue below which household and individual businesses, including many farm households, are outside VAT from VND 200 million to VND 500 million.

Import duty, credit, insurance and linkage support

Import duty. Under Article 16 of Law No. 107/2016/QH13, goods imported to create the fixed assets of a project in an incentivised sector or location, such as greenhouse structures, climate-control systems, irrigation equipment, cold stores and processing lines that are not produced domestically, are exempt from import duty on the basis of a list of exempt goods notified to customs before the first import, and the exemption is lost, with duty and interest, if the goods are sold or diverted (Customs and import duties; FAQ 37). The investor should confirm, against Decree No. 96/2026/ND-CP and the customs rules, that its agricultural line is an incentivised sector before relying on the exemption, and that imported plant varieties and animal breeds are permitted for import under the crop and livestock laws.

Credit. Decree No. 55/2015/ND-CP on credit policy for agricultural and rural development, as amended by Decree No. 116/2018/ND-CP and, from 1 July 2025, Decree No. 156/2025/ND-CP, allows credit institutions to lend without collateral up to VND 300 million to individuals and households, VND 500 million to cooperative groups and household businesses, VND 3 billion to farm owners and VND 5 billion to cooperatives and unions of cooperatives, and, since 1 July 2025, up to 70% of the value of an organic or circular-economy agricultural project or plan; the rules as amended in 2018 already allowed customers with high-tech agriculture projects or plans to borrow without collateral for 70% to 80% of the project's value. Approval of any loan remains the bank's credit decision.

Agricultural insurance. Decree No. 58/2018/ND-CP provides for State support of agricultural insurance premiums, and Decree No. 346/2026/ND-CP of 5 September 2026, in force from 20 October 2026, raises the maximum support to 95% of the premium for poor and near-poor households, 50% for other individual producers and 30% for qualifying agricultural production organisations, a category that covers enterprises, cooperative groups, cooperatives and unions of cooperatives meeting conditions on production linkages, product quality or high-tech application. It extends cover beyond the listed products (rice, rubber, coffee, cattle, pigs, poultry, shrimp, pangasius and others) to other key crops, species and forest trees, recognises index-based products, and leaves each provincial People's Council to decide the area, beneficiaries, risks, support levels and period within its budget.

Linkages. Decree No. 98/2018/ND-CP supports the lead enterprise in a qualifying linkage with cooperatives and farmers, through support for consultancy, infrastructure, seed and inputs, training and packaging, on conditions described in Agro-processing, food safety, cooperatives and contract farming.

How to assemble and claim an agricultural incentive package

1. Fix the activity and the locationClassify each income stream and confirm on the current Government list whether the commune is a difficult or extremely difficult area, or the site is in a high-tech agricultural zone.
2. Choose the most beneficial CIT levelCompare the exemption, the life-of-activity 10% or 15% rates and any new-project package; Article 12(1) of the CIT Law allows the most beneficial level for the same income.
3. Check high-tech statusIf the project relies on high technology, check its products and technologies against the 2026 lists and the criteria in Decree No. 260/2026/ND-CP, and diarise the expiry of any certificate issued under the 2008 law.
4. Record incentives in the IRC and the leaseHave the CIT, import duty and land rent incentives and their legal basis recorded in the IRC, and file the land rent exemption claim with the lease file.
5. Apply for Decree No. 57/2018/ND-CP support before investingFile the support dossier with the provincial Department of Finance and obtain the People's Committee's written commitment before the works are built, since payment follows acceptance.
6. Notify the exempt-goods listNotify customs of the list of duty-exempt fixed-asset goods before the first import, and keep the goods in use for the project.
7. Set up separate accountsAccount separately for exempt, preferential and ordinary income and for VAT on not-subject, 5% and 10% supplies, so that the incentive and the input VAT position can be proved at audit.
8. Keep qualifyingMonitor the location list, processing conditions and employment ratios; wrongly claimed amounts are recovered with late-payment interest.