DECREE NO. 320/2025/ND-CP - GUIDING THE IMPLEMENTATION OF THE LAW ON CORPORATE INCOME TAX 2025

On 15 December 2025, the Government promulgated Decree No. 320/2025/ND-CP detailing a number of articles and implementation measures of the Law on Corporate Income Tax No. 67/2025/QH15. This is a key subordinate legislative instrument that plays a central role in translating the principle based provisions of the new Corporate Income Tax Law into concrete and applicable mechanisms in practice.

Decree 320 was issued in the context of Vietnam’s tax legal system entering a phase of comprehensive reform, with the aim of simultaneously achieving three major objectives: (i) expanding the tax base and enhancing tax compliance, (ii) restructuring tax incentive policies in a more focused and targeted manner, (iii) aligning more closely with international practices in the context of Vietnam’s deeper participation in global tax commitments.

With its broad regulatory scope and high level of detail, Decree No. 320/2025/ND-CP is expected to have a direct and significant impact on corporate tax planning, tax finalisation, as well as investment and restructuring strategies of enterprises from 2026 onwards.

In this newsletter, W&A provides a selective analysis of the key provisions of Decree 320 that are particularly relevant to businesses:

1. Permanent Establishment 

2. Taxable Income and Offsetting of Income within the Tax Period.

3. Deductible Expenses for Determining Taxable Income.

4. Non Deductible Expenses for Determining Taxable Income.

5. Corporate Income Tax Rates.

6. Vietnamese Enterprises Investing Overseas.

7. Foreign Enterprises Earning Income in Vietnam.

8. Corporate Income Tax Incentives.

9. Other Incentive Cases.

10. Conditions for Applying Corporate Income Tax Incentives.

11. Income from Capital Transfer.

12. Income from Securities Investment.

13. Income from Real Estate Transfer.

14. Effectiveness and Transitional Provisions.

👉 Read the full article here:

W&A Newsletter on Decree 320 - Corporate Income Tax-2912-EN.pdf

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Recommendations from W&A

In the context of increasingly detailed corporate income tax regulations and heightened compliance requirements for the 2025 tax finalization season, enterprises are encouraged to proactively review their tax positions, assess potential risks, and prepare their tax documentation in a structured and consistent manner. W&A is ready to support clients with corporate income tax advisory and compliance services, tax health check reviews, and transfer pricing analysis and documentation, not only for the 2025 tax finalization but also for subsequent years, helping businesses manage tax risks effectively and align with their long term business strategies.