August 01, 10, Corporate Income Tax Law 2025 Officially effective, the new regulations bring many preferential policies to the business community. Correctly identifying these preferential mechanisms, tax exemptions, and reductions is not only a mandatory legal requirement for all businesses, but also helps proactively optimize costs and manage risks. This article systematizes the key regulations in Articles 12, 13, 14, and 15; helping to determine the scope of application by industry/profession – geographical area, the timeframe for enjoying incentives, and the principles of application for each specific type of investment project.
I. Principles and scope of application
1. Principles
According to the Article 12, Chapter III Corporate Income Tax Law 2025The corporate income tax incentives are implemented based on two criteria: Industry, occupation offers and area endow.
In cases where other laws providing corporate income tax incentives are inconsistent with this Law, the provisions of this Law shall apply, except for the Law on the Capital City and resolutions of the National Assembly on special and specific mechanisms and policies.
When a business is eligible for multiple different tax incentives for the same income, it is entitled to... Choose the most advantageous offer.
The government stipulates the application of tax incentives in the following cases:
- Cases where tax incentives are applied based on geographical location;
- Tax incentives in the fields of agriculture, forestry, fisheries, and salt production;
- In cases where the first tax period generates revenue or income from an enterprise's investment project (including new investment projects, expansion investments, high-tech enterprises, high-tech agricultural enterprises, and science and technology enterprises) and the period for which revenue/income is generated is less than 12 months and is eligible for tax incentives. (*)
💡 Understand correctly
(*) Many projects become operational in the middle of the year, and the first tax period is often less than 12 months. Given this reality, it is necessary to correctly determine the timeframe for applying tax incentives according to the relevant Articles and Clauses so that businesses do not suffer disadvantages in terms of the duration of their incentive entitlement.
Newly established businesses or those with investment projects resulting from mergers, consolidations, divisions, separations, changes in ownership, or changes in business type inherit the tax obligations (including penalties, if any) and corporate income tax incentives (including uncashed losses) of the business/project prior to the aforementioned transactions, provided they continue to meet the conditions for corporate income tax incentives and loss carryforward as stipulated by law.
2. Scope of Application
a) Preferential industries and occupations
The industries and professions eligible for corporate income tax incentives are stipulated in: Clause 2 Article 12 include:
|
Point |
Groups of industries and occupations eligible for corporate income tax incentives. |
|
1 |
High-tech applications, venture capital investment for high-tech development belonging to the list of high-tech technologies prioritized for investment and development as stipulated in the Law on High Technology; application of strategic technologies as prescribed by law; high-tech incubation, high-tech enterprise incubation; investment in the construction and operation of high-tech incubation facilities and high-tech enterprise incubation facilities. |
|
2 |
Software product manufacturing; manufacturing cybersecurity products and providing cybersecurity services in accordance with the law on cybersecurity; manufacturing key digital technology products and providing electronic equipment in accordance with the law on the digital technology industry; research and development, design, manufacturing, packaging, and testing of semiconductor chip products; building artificial intelligence (AI) data centers. |
|
3 |
Production of supporting industrial products List of priority industrial support products for development as stipulated by the Government, meeting one of the following criteria:
|
|
4 |
Production of renewable energy, clean energy, and energy from waste disposal; environmental protection; production of composite materials, lightweight building materials, and rare materials; production for national defense and security, and production of industrial mobilization products as prescribed by law on national defense, security, and industrial mobilization; production of key chemical industrial products and key mechanical products as prescribed by law. |
|
5 |
Investment in the development of water treatment plants, power plants, water supply and drainage systems, bridges, roads, railways, airports, seaports, river ports, airfields, train stations, and other particularly important infrastructure projects is decided by the Prime Minister. |
|
6 |
High-tech enterprises, high-tech agricultural enterprises as defined by the High-Tech Law; and science and technology enterprises as defined by the Law on Science, Technology and Innovation. |
|
7 |
Investment projects in the manufacturing sector must meet the following conditions:
|
|
8 |
Investment projects are eligible for special investment incentives and support as stipulated in Clause 2, Article 20 of the Investment Law. The Government shall specify the details regarding the timeframe for disbursing the total registered investment capital of these projects. |
|
9 |
Planting, caring for, and protecting forests; producing, propagating, and breeding plant and animal varieties; investing in post-harvest preservation of agricultural products, preservation of agricultural products, aquatic products, and food; producing, extracting, and refining salt, except for salt production as stipulated in Clause 1, Article 4 of the Corporate Income Tax Law 2025. |
|
10 |
Forestry cultivation. |
|
11 |
Products include crops, planted forests, livestock, aquaculture, and processed agricultural and aquatic products. |
|
12 |
Production of high-grade steel; production of energy-saving products; production of machinery and equipment for agriculture, forestry, fisheries, and salt production; production of irrigation equipment; production of animal feed for livestock, poultry, and aquatic animals. |
|
13 |
Manufacture and assembly of automobiles; manufacture of other digital technology products. |
|
14 |
Investing in and operating technical infrastructure to support small and medium-sized enterprises (SMEs), and SME incubation centers; investing in and operating co-working spaces to support innovative start-up SMEs as stipulated in the Law on Supporting Small and Medium-Sized Enterprises. |
|
15 |
People's credit funds, microfinance institutions, cooperative banks. |
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16 |
Cooperative societies and cooperative unions operate in the fields of agriculture, forestry, fisheries, and salt production. |
|
17 |
Socialization in the fields of education and training, vocational training, healthcare, culture, sports, and environment according to the list of types, scale criteria, and standards prescribed by the Prime Minister; and forensic examination. |
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18 |
Investing in the construction of social housing for sale, rent, or lease-purchase to eligible individuals who are entitled to social housing support policies as stipulated in the Housing Law. |
|
19 |
Published in accordance with the Publishing Law. |
|
20 |
The press (including advertising in newspapers) is regulated by the Press Law. |
Lookup table of 20 industries and professions eligible for corporate income tax incentives in 2025.
b) Preferential areas
According to the Clause 3 Article 12Tax-incentive areas for corporate income tax as stipulated by the Government, including:
- The area has particularly difficult socio-economic conditions;
- The area has difficult socio-economic conditions;
- Economic zones, high-tech zones, high-tech agricultural zones, and concentrated digital technology zones.
II. Preferential Tax Rates
1. Method of application
According to the Article 13The preferential corporate income tax rates are applied as follows:
|
STT |
Preferential tax rates |
Applicable cases |
|
1 |
10% in 15 years |
⮞ Income of enterprises from implementing new investment projects as stipulated in the regulations Points 1, 2, 3, 4, 5; Income of businesses belonging to score 6; ⮞ Income of enterprises from implementing investment projects belonging to the following categories points 7, 8; Income of enterprises from implementing new investment projects in areas with particularly difficult socio-economic conditions. ⮞ Income of enterprises from implementing new investment projects in high-tech zones, high-tech agricultural zones, concentrated digital technology zones; new investment projects in economic zones located in areas with difficult or extremely difficult socio-economic conditions; ⮞ In cases where an investment project in an economic zone is located in both tax-incentive and non-tax-incentive areas, the determination of tax incentives for this project shall be regulated by the Government. |
|
2 |
10% |
⮞ Income of the business from activities belonging to points 10, 11 in areas with difficult socio-economic conditions; ⮞ Income of the business from activities belonging to Points 9, 17, 18; ⮞ Publisher's income as stipulated by the Publishing Law ⮞ Income of cooperatives and cooperative unions operating in the fields of agriculture, forestry, fisheries, and salt production not located in tax-incentive areas (Clause 3, Article 12); ⮞ Income of press agencies (including advertising in newspapers) as stipulated by the Press Law |
|
3 |
15% |
Income of a business from its operations score 11 Not located in an area eligible for tax incentives as stipulated; Note: Income from processing agricultural and aquatic products as stipulated in this section must meet the conditions specified in Clause 1, Article 4 of the Corporate Income Tax Law 2025; |
|
4 |
17% over a 10-year period |
⮞ New investment project belonging to Points 12, 13, 14: ⮞ New investment projects implemented in areas with difficult socio-economic conditions; ⮞ New investment projects in economic zones must not be located in areas with difficult or extremely difficult socio-economic conditions. |
|
5 |
17% |
People's credit funds, microfinance institutions, cooperative banks |
Table of preferential corporate income tax rates for 2025
⚠️ Note:
The period for applying preferential tax rates to income from the implementation of new investment projects of enterprises as stipulated in Article 13 (including projects specified in point 7 according to the lookup table above) is calculated from the first year the new investment project of the enterprise generates revenue.
In cases where businesses are granted preferential tax certificates or confirmations after the revenue is generated, the period for applying preferential tax rates is calculated from the year the certificates were granted.
The certificates and preferential treatment confirmations include:
- Certificate of High-Tech Enterprise;
- Certificate of high-tech agricultural enterprise;
- Certificate of Science and Technology Enterprise;
- Certificate for high-tech application projects;
- Certificate of incentive for projects producing supporting industrial products.
2. Extend the period for applying preferential tax rates.
According to the Clause 6 of Article 13, The extension of the preferential tax rate application period is regulated as follows:
- The Prime Minister has decided to extend the period of application of preferential tax rates for a maximum of 15 years for the following projects:
- New investment projects belong to the Points 1, 2, 4, 5 Projects with a minimum investment capital of 6,000 billion VND and a significant socio-economic impact should be especially encouraged;
- Investment projects are regulated by score 7 meet one of the following criteria:
- Producing globally competitive goods and services, with annual revenue exceeding VND 20,000 billion no later than 05 years from the start of revenue generation from the investment project;
- Regularly employing over 6,000 workers as defined by labor laws;
- Investment projects in the field of economic and technical infrastructure include: Investment in the development of water treatment plants, power plants, water supply and drainage systems, bridges, roads, railways, airports, seaports, river ports, airfields, train stations, new energy, clean energy, energy-saving industries, and petrochemical projects.
- For new investment projects that are eligible for special investment incentives and support as stipulated in... score 8The Prime Minister decides to apply a tax rate reduction of no more than 50% of the tax rate stipulated in... Clause 1 Article 13The period of application of the preferential tax rate shall not exceed 1.5 times the period of application of the prescribed preferential tax rate and may be extended for no more than 15 years, but not exceeding the term of the investment project.
III. Tax Exemptions and Reductions
1. Target audience and timeframe
a) Exemption from corporate income tax for 04 years
According to the Clause 1 Article 14Businesses are exempt from corporate income tax for a maximum of 04 years and receive a 50% reduction in corporate income tax payable for a maximum of 09 subsequent years after the tax exemption period expires, for income of businesses falling under the following categories:
- Entitled to a 10% tax rate for 15 years as stipulated in Clause 1 Article 13;
- Socialization activities in the fields of education and training, vocational training, health, culture, sports, and environment according to the list of types, scale criteria, and standards prescribed by the Prime Minister; forensic examination in areas with difficult and extremely difficult socio-economic conditions;
- In cases not falling within the geographical area specified above, the tax exemption is granted for a maximum of 04 years, and a 50% reduction in the tax payable is granted for a maximum of 05 years following the expiration of the tax exemption period.
b) Exemption from corporate income tax for 02 years
According to the Clause 2 Article 14Businesses are exempt from corporate income tax for a maximum of 02 years and receive a 50% reduction in corporate income tax payable for a maximum of 4 subsequent years on income of businesses eligible for the 17% tax rate for a period of 10 years as stipulated in Clause 04, Article 13.
2. Start date of tax exemption and reduction
According to the Clause 4 Article 14The start dates for applying tax exemptions and reductions are stipulated as follows:
- Begin starting from the first year of taxable income from investment projects;
- Case No taxable income in the first 03 years, the period of tax exemption and tax reduction is starting from year 04.
In cases where a business is granted a Certificate or Confirmation of Preferential Treatment, the start date for applying tax exemptions or reductions is stipulated as follows:
- If the Certificate is issued after the income has been generated then the application period calculated from the year the Certificate was issued;
- If, in the year the Certificate was issued, the business no income then the application period starting from the first year of income generation;
- If in The first 03 years from the date the Certificate is issued. which businesses no taxable income then the application period starting from the 04th year since the Certificate was issued..
This regulation applies to certificates and confirmations such as:
- Certificate for high-tech application projects;
- Certificate of High-Tech Enterprise;
- Certificate of high-tech agricultural enterprise;
- Certificate of Science and Technology Enterprise;
- Certificate of incentive for projects producing supporting industrial products.
For new investment projects eligible for special investment incentives and support as stipulated in Clause 2, Article 20 of the Investment Law, the Prime Minister shall decide to extend the tax exemption and reduction period for a maximum of 1.5 times the tax exemption and reduction period stipulated in Clause 1, Article 14 of this Law.
3. Tax incentives for expansion investment projects
According to the Clause 5 Article 14:
a) For projects currently receiving incentives
- When businesses Expanding existing projects in prioritized sectors, occupations, and geographical areas. According to Article 12 and while still within the tax incentive period, the additional income from expanded operations is subject to these regulations. The discount is applied. as an existing project for the remaining incentive period, and not to be accounted for separately additional income beyond the income of the ongoing project.
- Project expansion includes: scaling up, increasing capacity, technological innovation, pollution reduction, or environmental improvement.
b) For projects whose incentive period has expired.
- In cases where the existing project's incentive period has expired, the additional income from the expansion investment will still be retained. tax exemption or reduction if meeting the criteria in Clause 6 of Article 14, but not eligible for preferential tax ratesThe exemption/reduction period for the additional income is equal to the exemption/reduction period applied to new investment projects in the same industry, profession, and geographical area eligible for corporate income tax incentives. The registered investment capital is calculated from the year the project is completed..
- Business & Investment must be accounted for separately. The additional income from expansion investment is subject to incentives. If separate accounting is not possible, the income from expansion investment is determined by the ratio between the original cost of the newly invested fixed assets put into use and the total original cost of the enterprise's fixed assets.
Note:
Tax incentives as stipulated in Clause 5 of this document. do not apply for cases of investment expansion due to mergers and acquisitions The business or investment project is currently in operation.
c) Application criteria
According to the Clause 6 Article 14An investment expansion project is eligible for incentives when the existing project's incentive period has expired, provided it meets one of the following criteria:
- The original cost of fixed assets increased at the time of completion of disbursement of registered expansion investment capital reaching the minimum level stipulated by the Government, corresponding to cases where the expansion project belongs to industries, professions, or geographical areas eligible for corporate income tax incentives;
- The proportion of the original cost of fixed assets at the time of completion of the disbursement of registered expansion investment capital must increase by at least 20% compared to the total original cost of fixed assets before the start of the expansion investment;
- The additional design capacity at the time of completion of disbursement of registered expansion investment capital must reach at least 20% compared to the design capacity before the expansion investment was implemented.
4. Other cases of tax exemption or reduction
According to the Article 15Other tax exemption and reduction cases include:
- Businesses engaged in manufacturing, construction, and transportation that employ a large number of female workers are entitled to a corresponding reduction in corporate income tax based on the additional expenses incurred for female employees.
- Businesses that employ a large number of ethnic minority workers are entitled to a reduction in corporate income tax corresponding to the additional expenses incurred for employing ethnic minority workers.
- Businesses transferring technology in priority sectors to organizations and individuals in economically and socially disadvantaged areas, or public service units providing public services in these areas, are entitled to a 50% reduction in corporate income tax calculated on income from technology transfer and income from providing public services in economically and socially disadvantaged areas.
- Businesses regulated by Paragraphs 2 and 3 of Article 10 According to the 2025 Corporate Income Tax Law, when newly established from a household business, the business is exempt from corporate income tax for two consecutive years from the time taxable income is generated;
- Public science and technology organizations and public non-profit higher education institutions are exempt from taxes as stipulated by the Government.
- The government will provide detailed regulations for this Article.
In the context of constantly evolving tax policies, the most effective approach remains: compliance as the foundation, data as the basis, and processes as the tool. Businesses should standardize accounting, establish timelines for tracking tax incentives, maintain complete documentation, and periodically review applicable policies to optimize costs and control risks. A well-structured tax strategy—integrated with financial and operational planning—will create a legal safety margin, improve cash flow, and enhance long-term competitiveness.