Vietnam government has given the major changes in tax occurring within a short period. From Jan2026, beside the update on new tax laws and regulations, Vietnam Manual will issue monthly Tax News giving summary of Official Dispatches that Tax authority responds to questions of Tax Payers.
1. Official Dispatch No. 6307/CT-CS dated December 26, 2025, of the Tax Department, on tax collection regarding the sale of loan collateral (replying to the Civil Judgment Enforcement Office – Area 6).
Pursuant to the provisions of Article 200 of the Law on Credit Institutions No. 32/2024/QH15, the tax payment by the securing party and the transferee related to the transfer of collateral for such bad debts shall be carried out in accordance with the provisions of tax laws.
According to the Law on Corporate Income Tax (CIT), in cases where Bac Nam Environmental Engineering Co., Ltd. has loan collateral consisting of automobiles, and the Judgment Enforcement Agency auctions these assets to handle bad debts, the income from the transfer of such assets shall be determined in accordance with the guidance in Clause 6, Article 7 of Circular No. 78/2014/TT-BTC.
2. Official Dispatch No. 6394/CT-CS dated December 29, 2025, of the Tax Department, regarding VAT policies (replying to Quang Ngai Provincial Tax Department).
In cases where an investment project complies with the provisions of the law on investment, satisfies the conditions for tax credit and tax refund for investment projects as prescribed by the Law on VAT, and has submitted a VAT refund dossier for investment projects in accordance with the law on tax administration, it shall be entitled to a VAT refund for the investment project.
3.Official Dispatch No. 6461/CT-NVT dated December 31, 2025, of the Tax Department, providing guidance on the issuance of code-based e-invoices by tax authorities on a transaction-by-transaction basis (replying to Hai Phong City Tax Department).
In cases where a business is subject to the enforcement measure of ‘suspension of invoice usage,’ it may .still be issued code-based e-invoices by the tax authority on a transaction-by-transaction basis, provided all regulatory conditions are met
4. Official Dispatch No. 6471/CT-CS dated December 31, 2025, of the Tax Department, on determining Corporate Income Tax (CIT) incentives for high-tech agricultural enterprises (replying to Hung Yen Provincial Tax Department).
In the case of investment expansion (supplementary projects) by a high-tech agricultural enterprise, the CIT incentives shall only be granted based on the original investment project’s criteria for high-tech agricultural enterprises for the remaining duration.
In cases where an enterprise elects to receive incentives based on the criteria for high-tech agricultural enterprises, once the incentive period under these criteria expires, it shall not be permitted to switch to the 15% preferential tax rate applicable to agricultural product processing activities.
Starting from the 2025 tax period, implementation shall be carried out in accordance with the provisions of the Law on Corporate Income Tax No. 67/2025/QH15 dated June 14, 2025, and Decree No. 320/2025/ND-CP dated December 15, 2025, of the Government, providing detailed regulations on a number of Articles and measures for the implementation of the Law on Corporate Income Tax.
5. Official Dispatch No. 63/CT-CS dated January 07, 2026, of the Tax Department, on the declaration of PIT (Personal Income Tax) from tax-exempt wages and salaries according to Resolutions (replying to Da Nang City Tax Department).
In cases where organizations or individuals paying income are subject to monthly or quarterly PIT declarations, they are responsible for submitting PIT declaration dossiers and fully declaring the tax withheld during that period if tax withholding occurs. If no PIT withholding occurs during the month or quarter, the submission of monthly or quarterly PIT declaration dossiers is not required. Regarding tax finalization, organizations or individuals paying income from wages and salaries are responsible for filing PIT finalization returns, regardless of whether tax withholding has occurred or not.
Regarding the PIT exemption under Resolution No. 136/2024/QH15, the Tax Department is currently analyzing tax returns and supporting declarations according to the plan proposed by the Da Nang City Tax Department. The Da Nang City Tax Department is requested to proactively coordinate with relevant agencies to monitor and supervise the tax declaration and payment of taxpayers.
6. Official Dispatch No. 174/CT-CS dated January 13, 2026, issued by the Tax Department regarding the adjustment and offsetting of Corporate Income Tax (CIT) payable (Response to 28 Hung Phu Joint Stock Company)
In the event that 28 Hung Phu Joint Stock Company has been issued a decision on administrative tax penalties by the Ho Chi Minh City Tax Department, and the Company determines that such administrative decision is not in accordance with the law, the Company shall proceed with a complaint following the prescribed procedures sent to the competent authorities as regulated.
7. Official Dispatch No. 177/CT-CS dated January 13, 2026, issued by the Tax Department regarding Tax Incentives (Response to Khanh Hoa Provincial Tax Department)
In principle, if an enterprise is currently enjoying Corporate Income Tax (CIT) incentives and generates income that qualifies for CIT incentives based on investment location or specific sectors as prescribed by CIT legal documents, while simultaneously meeting the conditions for production, extraction, and refining of salt under Law No. 32/2013/QH13 and Circular No. 78/2014/TT-BTC, the enterprise is entitled to select the most favorable incentive scheme as regulated. Therefore:
+ In the event that an enterprise’s tax incentive period based on location-based conditions has expired, it shall not be permitted to switch to applying tax incentives for income derived from the production, extraction, and refining of salt.
+ In the event that an enterprise is still within the period of tax incentives based on sector-specific or location-specific conditions, it is entitled to select the most favorable incentive scheme (based on the sector, the location, or the enterprise’s income from the production, extraction, and refining of salt) for the remaining incentive period of the ongoing project.
From the 2025 tax period, implementation shall be carried out in accordance with Corporate Income Tax Law No. 67/2025/QH15 dated June 14, 2025, and Government Decree No. 320/2025/ND-CP dated December 15, 2025, on Corporate Income Tax.
8. Official Dispatch No. 202/CT-CS dated January 13, 2026, issued by the Tax Department regarding tax policies (Response to Lam Dong Provincial Tax Department)
Foreign contractors granted a Taxpayer Identification Number (TIN) to pay Corporate Income Tax (CIT) under the direct method (as a percentage of taxable revenue) shall declare and pay Foreign Contractor Tax (CIT on machinery, equipment, and accompanying services) based on the signed contractor agreement with the project owner, provided that all prescribed conditions are factually met.
9. Official Dispatch No. 224/CT-CS dated January 14, 2026, issued by the Tax Department regarding electronic invoices (Response to Ho Chi Minh City Tax Department).
In principle, invoices must be issued in continuous numerical order, from the lowest to the highest number, within the same invoice series and invoice template symbol. The e-invoice system operates according to these regulations, whereby for a single seller (associated with a specific Taxpayer Identification Number), only one unique invoice exists for any given invoice series and template symbol.
10. Official Dispatch No. 284/CT-DNL dated January 16, 2026, issued by the Tax Department regarding Value Added Tax (VAT) declaration for investment projects (Response to Vietnam Electricity – EVN)
Effective from July 1, 2025, EVN and its Project Management Boards (PMBs) shall perform VAT declarations in accordance with Government Decree No. 181/2025/ND-CP dated July 1, 2025. In the event that from July 1, 2025, EVN assigns PMBs located in the same province or city as EVN to directly perform VAT declaration, deduction, and refund on behalf of EVN, such PMBs are entitled to deduct and claim VAT refunds for the investment projects as regulated.
11. Official Dispatch No. 296/CT-CS dated January 19, 2026, issued by the Tax Department regarding tax policies (Response to Microsoft Regional Sales Pte Ltd)
In the event that the cloud and online services provided by Microsoft Regional Sales Pte Ltd (headquartered in Singapore) are identified as telecommunications services under Clause 11, Article 3 of the Law on Telecommunications, they shall be subject to a Value Added Tax (VAT) rate of 10% effective from July 1, 2025.
12. Official Dispatch No. 645/CT-CS dated January 23, 2026 issued by the Tax Department regarding communication and support for the collection and payment of business license fees from January 1, 2026 (in response to Provincial and Municipal Tax Departments).
From January 1, 2026, taxpayers are not required to pay the business license fee for 2026 and subsequent years. Accordingly, taxpayers are not required to submit business license fee declarations for 2026 and the following years.
Provincial and Municipal Tax Departments are requested to organize communication and dissemination of this content to taxpayers to ensure the consistent implementation of the declaration and payment of the business license fee from 2026 onward. They are also required to review and apply tax administration measures in accordance with regulations to collect fully and accurately any business license fees payable for 2025 and prior years into the state budget.
13. Official Dispatch No. 692/CT-CS dated January 27, 2026 issued by the Tax Department regarding value-added tax (VAT) policy (in response to the Ninh Bình Provincial Tax Department).
From July 1, 2025, if cement and clinker products are not included in the Lists (Appendix I and Appendix II) issued together with Decree No. 181/2025/ND-CP, exported cement and clinker products shall be subject to value-added tax (VAT).Business establishments that have registered to pay VAT under the credit (deduction) method and have investment projects in accordance with the law on investment (including investment projects divided into multiple phases or multiple components), which are still in the investment phase and have uncredited input VAT of VND 300 million or more, shall be eligible for consideration of VAT refund in accordance with Law No. 48/2024/QH15 and Decree No. 181/2025/ND-CP.
In cases where a business establishment has an investment project that was initiated before July 1, 2025 and is still in the investment phase from the effective date of Decree No. 181/2025/ND-CP, the VAT refund provisions for investment projects as stipulated in Article 30 of Decree No. 181/2025/ND-CP shall apply.