2026 Corporate Income Tax Law Vietnam Foreign Investors

From October 1st, 2026, the 2026 Corporate Income Tax Law officially comes into effect, detailing many important provisions for businesses. Compared to the current Corporate Income Tax Law, the 2026 Corporate Income Tax Law has many new points, especially the addition of taxable subjects, expansion of tax incentives, detailed regulations on deductible expenses, etc. Below are some new contents that 2026 Corporate Income Tax Law Vietnam Foreign Investors need to be aware of.

1. Foreign Businesses Operating Through Digital Platforms and E-commerce Will Be Subject to Corporate Income Tax

The Corporate Income Tax Law of 2026, effective from October 1, 2026, has expanded the scope of Tax Obligations for E-commerce Enterprises Vietnam to include foreign organizations conducting business in Vietnam through electronic means. Accordingly, foreign businesses that do not have a registered office or permanent establishment in Vietnam but generate income from providing goods and services on e-commerce platforms, digital applications, or online platforms are subject to corporate income tax in Vietnam (Point d, Clause 2, Article 2, Corporate Income Tax Law 2026).

Notably, this law clarifies the principle for determining taxable income: all income originating from Vietnam will be subject to tax obligations, regardless of the business’s registered office or operating country.

This aims to ensure fairness in the tax environment and prevent revenue losses from cross-border business models.

Tax obligations for e-commerce enterprises vietnam

2. Addition of tax-exempt income groups in the environmental sector and green bonds

The Corporate Income Tax Law of 2026 has updated new regulations related to tax-exempt income groups, reflecting the direction of promoting green growth and a low-carbon economy. Specifically:

Tax-exempt group 1: Certain income from the environmental sector

Businesses will be exempt from corporate income tax on income arising from the first transfer of carbon credits or emission reduction certificates after issuance, if this transfer takes place within the framework of the domestic emissions market.

Tax-Exempt Income Category 2: Interest from Green Bonds

At the same time, interest from green bonds – bonds issued to finance environmentally friendly projects – is also included in the tax-exempt income category, along with income from the first transfer of green bonds after issuance.

3. Losses from Real Estate Transfers Can Be Offset Against Taxable Income

A notable change in the 2026 Corporate Income Tax Law is the provision allowing businesses to proactively offset losses from real estate transfers against income from other production and business activities, except for the portion currently enjoying tax incentives.

Specifically, if a real estate transfer results in a loss, the business can choose to deduct this loss from the profit from its main operations, and the remaining income after offsetting will be subject to the tax rate corresponding to the type of production and business that generated the income.

Note: Income from the transfer of mineral resources or the right to participate in mineral-related projects: investment in exploration, exploitation, processing, etc., must be declared separately and cannot be offset against other income in the same tax period.

CIT exemption categories for investment projects vietnam

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4. Shortening the tax exemption period for income from new technology products

A notable adjustment in the 2026 Impact of 2026 CIT Law on Multinational Accounting is the reduction of the tax exemption period for income from research and technological innovation activities. This regulation is stated in Clause 4, Article 4 of the 2026 Corporate Income Tax Law:

Thus, income from the transfer of scientific research results, technological development, digital transformation, or income from the sale of products created from new technology or from pilot production, including controlled pilot production, will only be exempt from tax for a maximum of 3 years, instead of 5 years as previously stipulated.

5. Preferential Tax Rates of 15% or 17% Specifically for Small and Medium-Sized Enterprises

One of the highlights of the 2026 Corporate Income Tax Law is the Tiered CIT Rates for Small Businesses Vietnam 2026. According to Article 10 of the 2026 Corporate Income Tax Law, the general tax rate is 20%. However, to reduce the burden of costs and promote growth for the small business sector, a 15% tax rate will apply to businesses with revenue not exceeding VND 3 billion/year. Businesses with revenue from VND 3 billion to VND 50 billion will be subject to a 17% tax rate.

However, this New Deductible Expense Rules Under CIT 2026 does not apply to related-party businesses if any related party does not meet the conditions to enjoy the preferential tax rate. This content is clearly stipulated in Clause 4, Article 18, Law on Corporate Income Tax 2026.

6. Addition of industries and professions eligible for CIT Exemption Categories for Investment Projects Vietnam

Many new fields have been added to the list of corporate income tax incentives. According to Articles 12 and 13 of the Law on Corporate Income Tax 2026, the most notable include:

  • Science and technology enterprises under the Law on Science and Technology 2013.
  • High-tech enterprises, high-tech agricultural enterprises under the Law on High Technology 2008.
  • Innovation activities.
  • Journalistic activities, including advertising in newspapers, as per the 2016 Press Law.
  • Investment in technical support facilities, small and medium-sized enterprise (SME) incubators, and co-working spaces supporting innovative startups, as per the 2017 Law on Supporting Small and Medium-Sized Enterprises.
  • Projects eligible for special investment incentives under Clause 2, Article 20, of the 2020 Investment Law.
  • Removal of certain sectors and professions from the list of incentives.

The Corporate Income Tax Law 2026 will officially take effect on October 1st, with many notable new points regarding taxable subjects, tax incentives, tax rates, deductible expenses, etc. Several sectors have been added to the list of eligible for incentives, while some outdated policies have been eliminated. These are important regulations that demonstrate a clearer direction in actively supporting small businesses and innovative enterprises, contributing to increased transparency and improved tax administration.
Please contact us if you need any support regarding new deductible expense rules under CIT 2026.

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