Vietnam's taxes are administered by the Tax Department under the Ministry of Finance, and almost every major tax law was rewritten in 2025 and 2026: a new Corporate Income Tax Law, VAT Law, Personal Income Tax Law and Tax Administration Law. The answers below reflect the position at the last review, for foreign-invested and Vietnamese companies alike.
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What is the corporate income tax rate in Vietnam?
The standard corporate income tax (CIT) rate is 20% of taxable profit under Law No. 67/2025/QH15 on Corporate Income Tax, which took effect on 1 October 2025 and applies from the 2025 tax period, with detailed rules in Decree No. 320/2025/ND-CP. Smaller enterprises pay 15% where annual revenue does not exceed VND 3 billion and 17% where it does not exceed VND 50 billion, and from the 2026 tax period Law No. 09/2026/QH16 and Decree No. 141/2026/ND-CP exempt enterprises with revenue of VND 1 billion or less, subject to conditions that exclude some related-party situations. Oil and gas activities are taxed at 25% to 50%, and certain rare mineral extraction at 40% or 50%. Domestic and foreign-invested companies pay the same rates, and tax losses can be carried forward for up to five years.
The standard VAT rate is 10%, with 5% for listed essential goods and services and 0% for exports, under Law No. 48/2024/QH15 on VAT, in force since 1 July 2025. Resolution No. 204/2025/QH15 and Decree No. 174/2025/ND-CP cut the 10% rate to 8% until 31 December 2026, except for telecommunications, finance, banking, securities, insurance, real estate, metals, most mining products and goods subject to special consumption tax. There is no separate registration threshold for companies: an enterprise is registered for tax on incorporation, and the credit method is compulsory once annual revenue reaches VND 1 billion. Returns are monthly by the 20th, or quarterly where prior-year revenue is up to VND 50 billion.
What tax is withheld on dividends, interest, royalties and fees paid abroad?
There is no Vietnamese withholding tax on dividends paid to foreign corporate shareholders out of after-tax profits, but most other Vietnam-sourced payments to foreign entities fall within foreign contractor tax (FCT), which the Vietnamese payer normally withholds. Under Circular No. 103/2014/TT-BTC, as amended by Circular No. 20/2026/TT-BTC from 12 March 2026, the deemed CIT element is 5% for interest, 10% for royalties, generally 5% for services and 2% for construction, often with a VAT element on services, and foreign corporate sellers of securities pay 0.1% of proceeds. Withheld FCT is declared within ten days of the payment. A tax treaty can reduce the CIT element, but no treaty is in force with the United States.
Which countries have double taxation agreements with Vietnam?
Vietnam has signed double taxation agreements with around 80 jurisdictions, including the United Kingdom, Singapore, Japan, South Korea, China, Hong Kong, France, Germany, the Netherlands, Luxembourg, Switzerland, Australia, Canada, India, Thailand and the United Arab Emirates. The agreement signed with the United States in 2015 is not yet in force. Treaties can reduce foreign contractor tax on interest, royalties and service fees and protect business profits earned without a permanent establishment. Since 1 July 2026, Circular No. 95/2026/TT-BTC, replacing Circular No. 205/2013/TT-BTC, sets out how treaties are applied, and relief must be claimed by filing a dossier with the tax authority, so check the treaty and the substance of your holding company first.
Is there capital gains tax when I sell shares or capital in a Vietnamese company?
Yes. Since Decree No. 320/2025/ND-CP took effect on 15 December 2025, a foreign corporate seller of capital in a Vietnamese company pays CIT at 2% of the gross sale proceeds, replacing the former 20% tax on net gains, and indirect transfers are also taxable. Sales of securities by foreign corporate sellers remain taxed at 0.1% of proceeds. Intra-group restructurings can be exempt where the ultimate owner is unchanged and no gain arises. Circular No. 20/2026/TT-BTC gives guidance and Circular No. 21/2026/TT-BTC a declaration form. Vietnamese companies are taxed on the net gain as ordinary income, and individuals under the personal income tax rules. Model the exit cost, including any treaty position, before investing.
Have there been recent tax changes foreign investors should know about?
Yes, many. The new CIT Law (No. 67/2025/QH15) applies from the 2025 tax period, with lower SME rates and a 2% tax on gross proceeds for foreign sellers of capital. Resolution No. 107/2023/QH15 and Decree No. 236/2025/ND-CP impose a 15% global minimum tax on groups with consolidated revenue of at least EUR 750 million, from the 2024 financial year. From 1 January 2026 the business licence fee and presumptive (lump-sum) tax for household businesses were abolished under Resolution No. 198/2025/QH15, new PIT brackets apply, and Law No. 09/2026/QH16 exempts enterprises with annual revenue up to VND 1 billion from CIT. The new PIT Law (No. 109/2025/QH15) and Tax Administration Law (No. 108/2025/QH15) took effect on 1 July 2026, with new transfer pricing and treaty rules.
Employment income of tax residents is taxed progressively under Law No. 109/2025/QH15 on Personal Income Tax, whose salary rules apply from the 2026 tax year: 5% on monthly taxable income up to VND 10 million, 10% up to VND 30 million, 20% up to VND 60 million, 30% up to VND 100 million and 35% above that. Monthly deductions are VND 15.5 million for the taxpayer and VND 6.2 million per dependant. You are resident if present for 183 days in a calendar year or in 12 months from arrival, or if you have a registered or leased home in Vietnam. Residents are taxed on worldwide income; non-residents pay a flat 20% on Vietnam-sourced employment income. Employers withhold monthly.
What are the transfer pricing and interest deduction rules?
Related-party transactions must be priced at arm's length. From 1 July 2026, applying to the 2026 tax year, Decree No. 255/2026/ND-CP replaces Decree No. 132/2020/ND-CP and its amending Decree No. 20/2025/ND-CP. Parties are generally related through 25% ownership or significant financing or control. Net interest expense is deductible only up to 30% of EBITDA, with the excess carried forward for up to five years; credit institutions, insurers, ODA and government concessional loans are among the exclusions. Related-party disclosures are filed with the annual CIT return, local and master files must be ready, and country-by-country reporting follows a EUR 750 million group threshold. There is no separate debt-to-equity thin capitalisation ratio.
Monthly VAT and PIT withholding returns are due by the 20th of the following month, or by the last day of the month after the quarter for quarterly filers. Provisional CIT is paid quarterly by the 30th of the month after each quarter, and the four instalments must together reach at least 80% of the final liability. The annual CIT finalisation return, filed with audited financial statements where required, and the employer's PIT finalisation are due by the last day of the third month after year end; individuals finalising their own PIT have until the end of the fourth month. Foreign contractor tax is declared within ten days of payment. The annual business licence fee was abolished from 2026.
What are the penalties for late filing or payment, and how are tax disputes resolved?
Late payment attracts interest of 0.03% a day on the unpaid tax, a rate kept by Law No. 108/2025/QH15 on Tax Administration (effective 1 July 2026). Late filing is fined according to the delay, up to VND 25 million; understated tax attracts a 20% penalty on the shortfall, and tax evasion a fine of one to three times the tax evaded, under Decree No. 125/2020/ND-CP as amended by Decree No. 310/2025/ND-CP. You can complain to the tax authority that issued a decision, generally within 90 days of receiving it, and escalate a rejected complaint, or sue in the people's court (since 1 July 2025 usually a regional people's court at first instance). The decision generally remains enforceable meanwhile.
Ask the Be Vietnam Wise advisor. It checks official Vietnamese sources and points you to the governing law, or read how to find and check a Vietnamese lawyer.
This page gives legal and tax information, not legal advice. Rates, thresholds and procedures change; the answers are re-checked against official sources every month, but you should confirm anything important with the relevant authority or a licensed Vietnamese lawyer before you act.