Updated 13 October 2026. Businesses with annual revenue of no more than VND 10 billion get a 30% reduction in the corporate income tax (CIT) payable for 2026 and 2027. This is set out in Resolution No. 43/2026/QH16, in force from 24 August 2026.
The policy clearly benefits small businesses. Even so, there are three points to understand before the year-end tax finalisation: how revenue is determined, how the reduction works for businesses already receiving tax incentives, and the anti-splitting rule that stops businesses getting under the threshold artificially. This article follows the text passed by the National Assembly and gives the current status of the implementing decree.
- A 30% reduction in the CIT payable for 2026 and 2027, for businesses with annual revenue of no more than VND 10 billion.
- Businesses already receiving tax incentives still get the reduction, calculated on the tax left after the incentive.
- Businesses split or separated after 24 August 2026 do not get the reduction if their combined revenue after the split exceeds VND 10 billion.
- Businesses with revenue of VND 1 billion or less are already exempt from CIT.
- The implementing decree has not been issued. Wait for guidance on how revenue is determined and on the filing procedure.
Legal basis and status of guidance
The direct legal basis for the reduction is Resolution No. 43/2026/QH16. As of 13 October 2026, the implementing decree had not been issued. To work out how much a business actually pays, read Resolution 43 together with the current rules on tax rates and the exemption threshold.
This article covers CIT only. The 30% reduction in personal income tax for household and individual businesses under the same Resolution will be covered by FC Legal in a separate article.
| Document | Relevant content | Status |
|---|---|---|
| Resolution No. 43/2026/QH16 | 30% reduction in CIT payable for 2026 and 2027 for businesses with annual revenue of no more than VND 10 billion | In force from 24 August 2026 |
| Law on Corporate Income Tax No. 67/2025/QH15, Article 10 | Tax rates of 15% (annual revenue of no more than VND 3 billion) and 17% (over VND 3 billion to VND 50 billion), based on revenue of the immediately preceding tax period | In force from 1 October 2025 |
| Law No. 09/2026/QH16, Article 3 (adding Clause 14a to Article 4 of the CIT Law) and Decree No. 320/2025/ND-CP as amended by Decree No. 141/2026/ND-CP | CIT exemption for businesses and organisations with total annual revenue of VND 1 billion or less | Law No. 09/2026/QH16 in force from 24 April 2026; the amendments to the CIT Law apply from 1 January 2026 |
| Decree detailing Resolution 43 | How revenue is determined, filing procedure, treatment of provisional tax already paid | Not yet issued. The Ministry of Finance has consulted on a draft (Official Letter No. 13905/BTC-CST dated 5 September 2026). The Prime Minister has instructed that it be submitted for issuance immediately |
Content that appears only in the draft decree is not yet law. This article treats as rules only what is in Resolution 43, and says clearly when it refers to the draft.
Which businesses qualify?
Under Clause 2, Article 1 of Resolution 43, a business must meet both conditions:
- It is an enterprise or organisation established under Vietnamese law.
- Its annual revenue for 2026 or 2027 is no more than VND 10 billion.
The Resolution uses the words “no more than”, so revenue of exactly VND 10 billion still qualifies.
Points awaiting the implementing decree
The Resolution does not yet set out the following points in detail. Wait for the implementing decree before finalising your tax figures:
- Which revenue figure is used to test the VND 10 billion threshold (total revenue on the finalisation return, and whether financial income and other income are included).
- How revenue is annualised for newly established businesses or those operating for less than 12 months in the year.
- Whether the threshold is tested separately for each year. The Resolution refers to revenue “of 2026, of 2027”, so the common reading is that each year is tested separately. For example, with revenue of VND 9 billion in 2026 and VND 12 billion in 2027, the reduction applies for 2026 but not for 2027. This reading needs to be confirmed by the decree.
The 15% or 17% tax rate is set by revenue of the immediately preceding year. Resolution 43, by contrast, looks at revenue of 2026 and 2027 themselves. These are different reference points, so check each condition separately.
Which group is your business in?
Find your group in the table below. Businesses with revenue of VND 1 billion or less are already exempt from CIT, so they do not need the 30% reduction.
| Total annual revenue | CIT rate | Reduction under Resolution 43 | Effective rate after reduction |
|---|---|---|---|
| VND 1 billion or less | Exempt | Not applicable | 0% |
| Over VND 1 billion to no more than VND 3 billion | 15% | 30% reduction | 10.5% |
| Over VND 3 billion to no more than VND 10 billion | 17% | 30% reduction | 11.9% |
| Over VND 10 billion to no more than VND 50 billion | 17% | No reduction | 17% |
The effective rate is the tax rate multiplied by 70% (15% × 70% = 10.5%; 17% × 70% = 11.9%), for businesses with no other incentives. The table is simplified: the tax rate is based on the previous year’s revenue, while the exemption threshold and the VND 10 billion threshold may be tested against different reference points, as explained above.
An FC Legal lawyer will discuss it with you and propose a suitable approach.
How to calculate the reduction
The reduction is 30% of the CIT payable. It is not 30% of the tax rate or 30% of income. If the business already receives a tax incentive, the 30% reduction is calculated on the tax still payable after the incentive.
Illustrative example (revenue, income and incentive figures are assumed; tax rates under Article 10 of the CIT Law 2025):
| Step | Business A | Business B | Business C (with a 50% tax reduction incentive) |
|---|---|---|---|
| 2026 revenue (previous year in the same band) | VND 2.5 billion | VND 8 billion | VND 8 billion |
| Taxable income | VND 300 million | VND 1 billion | VND 1 billion |
| Tax rate | 15% | 17% | 17% |
| Tax at the applicable rate | VND 45 million | VND 170 million | VND 170 million |
| Less existing tax incentive | 0 | 0 | VND 85 million |
| Tax payable before Resolution 43 | VND 45 million | VND 170 million | VND 85 million |
| 30% reduction under Resolution 43 | VND 13.5 million | VND 51 million | VND 25.5 million |
| Tax still payable | VND 31.5 million | VND 119 million | VND 59.5 million |
Legal basis: second paragraph, Clause 2, Article 1 of Resolution No. 43/2026/QH16.
According to press reports, the draft implementing decree proposes calculating the reduction on all of the business’s income, regardless of the tax calculation method. This is not yet law and will be updated when the decree is issued.
Splitting a business to get the reduction: not accepted
A business formed by a split or separation after 24 August 2026 does not get the reduction if the combined revenue of the businesses after the split exceeds VND 10 billion. This rule is in Clause 2, Article 1 of Resolution 43 itself.
Example: Company X has revenue of about VND 16 billion a year. In October 2026, X splits into two companies, each with revenue of about VND 8 billion. Combined revenue after the split is still VND 16 billion, which is over VND 10 billion. So neither new company gets the reduction, even though each is below the threshold.
Points to note:
- The rule only applies to splits and separations after 24 August 2026. Businesses that split before then are not caught by this exclusion.
- The Resolution only refers to a “split or separation of an enterprise”. It does not mention setting up a new company to move revenue across gradually, or other forms of restructuring. However, Article 11 of Decree No. 320/2025/ND-CP (guiding the CIT Law 2025) does not allow the 15% and 17% rates for a subsidiary or affiliated company if a company in the affiliated relationship does not meet the conditions. Get advice before restructuring.
Procedure and risks at year-end finalisation
Resolution 43 does not set out a filing procedure. This will be set by the implementing decree. Businesses should not apply the reduction themselves before there is official guidance on the forms and the revenue figure to use.
Three risks to prepare for now:
- Misjudging revenue when paying provisional tax. A business with revenue close to VND 10 billion may apply the reduction provisionally, then find at year end that actual revenue is over the threshold. It may then have to pay the tax it had provisionally reduced. Track cumulative revenue every quarter.
- Recording revenue in the wrong period. Delaying invoices or pushing revenue recognition into the next year to stay under the threshold may be adjusted by the tax authority on inspection.
- Records supporting tax incentives. Businesses receiving tax incentives need complete incentive records, because the 30% reduction is calculated after the incentive.
The specific consequences (back tax, late payment interest, penalties) will depend on the implementing decree and the current tax administration rules.
Frequently asked questions
Which years does the 30% CIT reduction apply to?
The 2026 and 2027 tax periods (Clause 1, Article 2 of Resolution No. 43/2026/QH16).
Does a business with revenue of exactly VND 10 billion qualify?
Yes. The Resolution refers to revenue of “no more than VND 10 billion”.
Can a business already exempt or receiving reductions under investment incentives get a further reduction?
Yes. The 30% reduction is calculated on the tax still payable after the incentive. If the business is in a period of full tax exemption, there is no tax payable left to reduce.
Do foreign-invested businesses qualify?
Resolution 43 applies to enterprises and organisations “established under Vietnamese law” and has no clause excluding foreign-invested businesses. For a similar policy, the incentives for small and medium-sized enterprises under Resolution No. 198/2025/QH15, some local tax authorities had issued guidance excluding FDI businesses. However, the Tax Department later confirmed in Official Letter No. 3896/CT-CS dated 11 June 2026 that foreign ownership is not a ground for exclusion. So FDI businesses established in Vietnam have a basis to claim the reduction under Resolution 43, but should check the implementing decree once it is issued.
What about businesses with revenue below VND 1 billion?
Businesses and organisations with total annual revenue of VND 1 billion or less are exempt from CIT under Clause 14a, Article 4 of the CIT Law (added by Law No. 09/2026/QH16) and Decree No. 320/2025/ND-CP as amended by Decree No. 141/2026/ND-CP. So this group does not need the 30% reduction.
Has the implementing decree been issued?
As of 13 October 2026, the decree had not been issued. The Ministry of Finance has consulted on a draft, and the Prime Minister has instructed that it be submitted to the Government for issuance immediately.
See also: Proactive compliance in 2026: what businesses need to do as tax, personal data and employment law change together (available in Vietnamese).
Make sure the tax reduction does not create new risks
A tax reduction only really helps when your records, contracts and revenue recognition do not create risk when the tax authority inspects. FC Legal supports you in the spirit of SPC: Safety · Protection · Care.
- Legal health check: review your corporate structure, internal transactions and tax incentive records to establish whether you qualify for the reduction and which risks to deal with before finalisation.
- Advice before restructuring: a legal assessment before splitting, separating, setting up a new company or changing your business model, so you do not fall into the exclusion.
- In-house counsel on retainer: ongoing support, updates when the implementing decree is issued, and standardised contracts and internal records.
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Reviewed by the FC Legal legal team. This article is for reference only and does not replace tax or legal advice on a specific case.
