Summary: Six separate Vietnamese tax instruments took or take effect between July 2025 and July 2026 — a new VAT Law, a new CIT Law, a new Personal Income Tax Law, a new Transfer Pricing Decree, the Global Minimum Tax regime, and a new regional minimum wage. None of them individually made headlines outside Vietnam. Together, they change the compliance calendar, the incentive math, and the related-party risk profile for every FDI company operating here in 2026.
By ECOVIS Vietnam Law | Last reviewed: 2026-07-15
“The mistake I see most often is treating these as six separate compliance updates. They are one event: Vietnam recalibrated its entire tax base in a 12-month window, and a CIT incentive registered under the old rules can be quietly neutralized by a decree a company’s tax team never read.” — Attorney Vu Manh Quynh, Founder & Managing Partner, ECOVIS Vietnam Law
Why This Matters Now
Vietnam’s tax framework does not usually move this much in a single cycle. Between 1 July 2025 and 1 July 2026, six instruments took effect or were extended: the VAT Law (48/2024/QH15), the CIT Law (67/2025/QH15), the Global Minimum Tax regime (Resolution 107/2023/QH15 + Decree 236/2025/NĐ-CP), a new Personal Income Tax Law, a new Transfer Pricing Decree (255/2026/NĐ-CP), and a new regional minimum wage (Decree 293/2025/NĐ-CP).
For a CFO running payroll, pricing intercompany flows, and defending a CIT incentive position, the practical issue is not any single change. It is that a company’s 2026 tax position depends on all six reading consistently — an incentive claimed under the new CIT Law can be reduced to nothing by the Global Minimum Tax top-up if the group is in scope; a related-party map drawn up under the old Transfer Pricing Decree may already be incomplete under the new one.
What Changed — By Tax Type
Corporate Income Tax (Law No. 67/2025/QH15, effective 1 October 2025, applies from tax year 2025). The standard 20% rate is unchanged, but the incentive architecture is not. Location inside an industrial zone alone no longer qualifies a project for CIT incentives — a change that affects a large share of manufacturing FDI structured on that basis. The old incentive tied to a VND 6,000 billion investment threshold has been eliminated. New 10%-for-15-years incentives apply to high-tech application, venture capital, supporting industries, renewable energy, software, AI, semiconductors and R&D centres, and qualifying R&D expenses are now deductible at up to 200% of actual cost.
Global Minimum Tax (Resolution 107/2023/QH15, Decree 236/2025/NĐ-CP, effective 15 October 2025). MNE groups with consolidated revenue above EUR 750 million in two of the preceding four years are now subject to a 15% minimum effective tax rate in Vietnam, via a Qualified Domestic Minimum Top-up Tax and an Income Inclusion Rule. This is not in most companies’ existing tax models, and it interacts directly with the CIT incentives above: a group holding a 10% preferential rate can still owe a top-up tax to reach the 15% floor. A transitional safe harbor applies for fiscal years beginning before 31 December 2026, provided a simplified effective tax rate of at least 17% is met for 2026.
Value Added Tax (Law No. 48/2024/QH15, effective 1 July 2025). The VND 20 million non-cash-payment threshold for input VAT credit is gone — non-cash payment evidence is now required regardless of invoice value. Foreign e-commerce and digital suppliers without a Vietnam permanent establishment now pay 10% VAT, up from 5%. Separately, Resolution 204/2025/QH15 extends the temporary 8% rate (down from the 10% standard rate) through 31 December 2026, though real estate, telecoms, and the financial/insurance sectors remain excluded from that reduction.
Personal Income Tax (new PIT Law, phased from 1 January 2026, in force 1 July 2026). The personal deduction rises from VND 11 million to VND 15.5 million per month; the dependent deduction rises from VND 4.4 million to VND 6.2 million. The number of progressive brackets drops from seven to five, and the top 35% bracket now starts above VND 100 million per month rather than VND 80 million. For payroll teams, this is a mid-year recalculation exercise, not a January-only update — the effective date split between salary/wage provisions (1 January 2026) and the rest of the law (1 July 2026) is easy to miss.
Transfer Pricing (Decree 255/2026/NĐ-CP, effective 1 July 2026). This replaces both Decree 132/2020/NĐ-CP and Decree 20/2025/NĐ-CP outright, not as a partial amendment. The three-tiered documentation structure and the 30% EBITDA interest-expense cap carry over unchanged. What is new: a capital transfer of at least 25% of owner’s equity, or a loan of at least 10% of owner’s equity involving a managing or controlling individual, arising at any point during the tax year, can itself create related-party status — independent of any ownership structure fixed at incorporation. A company’s related-party position is no longer a static fact set at company formation; it can change mid-year through financing and capital activity that finance teams may not flag as a tax event.
Regional Minimum Wage (Decree 293/2025/NĐ-CP, effective 1 January 2026). A 7.2% average increase; Region I rises to VND 5,310,000 per month. This resets the SI/HI/UI contribution cap (20x the regional minimum wage) referenced in payroll budgets built on the prior decree’s figures.
The Practical Issue: These Six Changes Don’t Operate in Isolation
The most common execution mistake is not missing any one of these changes — most in-house teams eventually catch each one individually. The mistake is reviewing them on six separate timelines instead of one.
A CIT incentive registered under the new Law 67/2025/QH15 framework needs to be checked against Global Minimum Tax exposure before a group treats the incentive rate as the effective rate. A transfer pricing file built under the old Decree 132/2020 assumptions needs to be re-tested against Decree 255/2026’s transaction-triggered related-party category — a shareholder loan signed in Q2 2026 can create a related-party relationship that did not exist in Q1. A payroll system updated for the new minimum wage needs the PIT bracket change layered in on a different effective date, not the same one.
Recommended CFO Action Plan for 2026
- Map every CIT incentive currently registered and test it against the eliminated industrial-zone and VND 6,000bn thresholds under Law 67/2025/QH15.
- If the group’s consolidated revenue exceeds EUR 750 million, run a Global Minimum Tax exposure check before relying on any preferential CIT rate as the effective rate.
- Rebuild the related-party relationship map under Decree 255/2026/NĐ-CP — specifically, flag capital transfers and shareholder loans occurring during the 2026 tax year, not just the ownership structure at incorporation.
- Update payroll systems for the new PIT brackets and deduction amounts on their correct effective dates (1 January 2026 for salary/wage provisions, 1 July 2026 for the balance of the law) and for the new regional minimum wage.
- Confirm which supplies still qualify for the 8% VAT rate through 31 December 2026, and which have moved to a different rate classification under the new VAT Law.
- Re-verify input VAT credit support now that the VND 20 million non-cash-payment threshold no longer applies.
Frequently Asked Questions
Does the new CIT Law change the 20% standard corporate tax rate?
No. The standard rate remains 20%. What changed is which projects qualify for preferential rates below that — industrial zone location alone is no longer sufficient, and the VND 6,000 billion large-manufacturing threshold has been removed.
If my group already holds a 10% preferential CIT rate, does Global Minimum Tax still apply?
It can. If the group’s consolidated revenue exceeds EUR 750 million in two of the preceding four years, a Qualified Domestic Minimum Top-up Tax can bring the effective rate up to the 15% floor regardless of the preferential rate on paper.
Do we need to redo our transfer pricing documentation from scratch under Decree 255/2026?
No — the three-tiered documentation structure (Local File, Master File, CbCR) and the 30% EBITDA interest cap carry over. What needs re-testing is whether any related-party relationship arose during the 2026 tax year under the new transaction-triggered category (capital transfers ≥25% of equity, or loans ≥10% of equity involving a controlling individual).
When exactly do the new PIT deduction amounts take effect?
Provisions on salary, wage and business income take effect from 1 January 2026; the remainder of the new PIT Law takes effect 1 July 2026. Payroll teams should apply the January date for the deduction and bracket changes.
Is the 8% VAT rate permanent?
No — it is a temporary reduction from the 10% standard rate, currently extended through 31 December 2026 under Resolution 204/2025/QH15. Real estate, telecoms, and financial/insurance services are excluded from the reduction regardless.
Does an ordinary bank loan create a related-party relationship under the new Transfer Pricing Decree?
No, where the lender is a licensed credit institution that does not directly or indirectly manage or control the borrower — this carve-out is retained and clarified under Decree 255/2026/NĐ-CP.
ECOVIS Advisory Angle
ECOVIS Vietnam Law recommends a 2026 Tax Readiness Review for FDI companies and multinational groups with registered CIT incentives, related-party transactions, intercompany financing, or consolidated group revenue near the EUR 750 million Global Minimum Tax threshold. The review maps incentive exposure against Global Minimum Tax, rebuilds the related-party relationship map under Decree 255/2026, and confirms payroll and VAT classification changes are applied on the correct effective dates.
Attorney Vu Manh Quynh is the Managing Partner of ECOVIS Vietnam Law, advising international investors on Foreign Direct Investment (FDI), corporate governance, and regulatory compliance in Vietnam.
This material is for general informational purposes only and does not constitute legal, tax or professional advice. Investors should seek specific advice based on their business sector, ownership structure and investment location in Vietnam.
