Vietnam

Inventory valuation

At present, there are no provisions for valuing inventories or determining inventory flows. There is a separate tax guidance for making provision for inventories and certain other provisions.

Asset revaluation

Gains from the revaluation of assets for the purposes of capital contribution or transfer upon division, de-merger, consolidation, merger, or conversion of business are subject to the standard CIT rate.

Capital gains

Gains derived from the sale of interest in a Vietnam company are in many cases subject to 20% CIT. This is generally referred to as capital gains tax (CGT) although it is not a separate tax as such. The taxable gain is determined as the excess of the sale proceeds less historical cost (or the initial value of contributed charter capital for the first transfer) less transfer expenses.

Recently there has been a move to tax not only the transfer of interest in a Vietnamese entity, but also the transfer of interest in overseas parents (direct or indirect) of a Vietnamese company. Under the 2019 tax administration law and its guiding instruments, the taxing position may be strengthened.

Transfers of securities (bonds, shares of public joint stock companies, etc.) by a foreign entity are subject to CIT on a deemed basis at 0.1% of the total sales proceeds. Gains derived by a resident entity from the transfer of securities, however, are taxed at 20%.

On 11 June 2024, a draft law on CIT was released for public consultation. The draft law includes a proposal to drastically amend the Capital Gains Tax regime effective from 1 January 2026. Accordingly, tax on securities transfers would remain unchanged but transfers of capital would be subject to CGT at the rate of 2% on the sales proceeds, irrespective of whether there is a gain or not.

Dividend income

Dividends received from investments in other companies in Vietnam are not subject to CIT if they have been subject to CIT at the investee companies.

Interest income

Interest income is taxed at the standard CIT rate.

Certain types of interest income are entitled to tax incentives granted to the investment project, depending on the conditions on which tax incentives are granted.

Royalty income

Currently, royalty income is subject to tax at the standard CIT rate.

Other significant items

Tax incentives that are available for investment in encouraged sectors do not apply to other income (except for income that directly relates to the incentivised activities, such as disposal of scrap), which is broadly defined.

The following income items are subject to the standard CIT rate and are not entitled to tax incentives (including preferential tax rate and exemption/reduction):

• Income from transfer of the right to make capital contribution; income from transfer of immovable property (except for income from investment in social houses); income from transfer of investment projects, transfer of the right to take part in investment projects, and transfer of the right to exploration and exploitation of minerals.
• Income from activities of prospecting for, exploration of, and exploitation of oil, gas, and other rare and precious resources; income from activities of exploiting minerals.
• Income from providing services subject to SST in accordance with the provisions of the law on SST.

Foreign income

Foreign income, under the domestic tax law, is subject to the standard CIT rate with tax credits available (see Foreign tax credit in the Tax credits and incentives section).

Foreign income shall be taxed when earned. There are no provisions for tax deferral or preferential tax rates for foreign income.