Tax & Legal Newsletter | September 2025
Vietnam Tax and Legal Updates for September 2025
Key updates covering Law No. 90/2025/QH15, input VAT deduction requirements for deferred or installment payments, and personal income tax treatment of mid-shift meal expenses.
This September 2025 newsletter highlights important tax and legal developments that businesses operating in Vietnam should monitor, particularly in relation to VAT, export and import duties, input VAT deduction documentation and employee welfare-related personal income tax treatment.
Contents
01
Law No. 90/2025/QH15
On 25 June 2025, the National Assembly issued Law No. 90/2025/QH15, amending and supplementing a number of articles of eight laws in the fields of finance, investment, bidding and customs. The law includes amendments to the Law on Value Added Tax and the Law on Export and Import Duties, and officially took effect on 1 July 2025.
The changes relating to VAT and export-import duties are expected to improve consistency across tax regulations, reduce overlapping incentives, support a more transparent investment environment and enhance state management efficiency.
1. Value Added Tax Law
| Content | Old regulation Before 1 July 2025 | New regulation From 1 July 2025 |
|---|---|---|
| Taxable price of imported goods | Taxable price = import price + import duty + special consumption tax, if any + environmental protection tax, if any. | Supplementary import duty is added, if any. Taxable price = import price + import duty + supplementary import duty, if any + special consumption tax, if any + environmental protection tax, if any. |
| VAT exemption | Certain goods and services used for scientific and technological research were exempt from or not subject to VAT. | The scope is adjusted to align with the Law on Export and Import Duties. The VAT exemption scope is narrowed and shifted to export-import duty incentives to avoid duplication. |
| VAT refund threshold for exported goods and services | Input VAT not yet deducted from VND 300 million or more is eligible for refund. | The VND 300 million threshold is retained. |
| Enterprises with both domestic and export activities | Regulations on the allocation of input VAT for export activities were not clear. | The principle for allocating input VAT is clarified. Only the portion directly related to export activities is eligible for refund. |
| Application submission method | Applications could be submitted in paper or electronic form, depending on the case and the tax authority. | Applications must be submitted fully through the tax authority’s electronic portal. |
| Risk management in tax refunds | No specific mechanism; tax administration mainly relied on post-refund inspection or audit. | A risk management mechanism is added. The tax authority may temporarily suspend processing when suspicious signs are detected. |
| Tax refund processing time | 6 working days for refund first and inspect later, or 40 days for inspect first and refund later. | The timeframe is retained but closely linked to the risk management mechanism, with priority for well-compliant businesses. |
| Investment project refund | Eligible for refund when an investment project in the investment phase has undeducted input VAT of VND 300 million or more. Conditions were not yet strict. | Additional conditions apply. The project must have a valid investment license and non-cash payment documents, while high-tax-risk enterprises may be excluded. |
2. Law on Export Tax and Import Tax
| Content | Old regulation | New regulation from 1 July 2025 |
|---|---|---|
| Import tax exemption for IT | Raw materials, supplies and components not domestically produced and used for manufacturing IT products, software and digital content were exempt from tax. | This exemption is abolished. |
| Exemption for research and high technology | Not clearly regulated. | Tax exemption is added for specialized machinery, equipment, materials, scientific documents, books and imported raw materials serving scientific research, innovation and the digital technology industry. |
| Specific tax schedule | Applied according to Decree No. 26/2023 and previous regulations. | Updated under new decrees, including Decree No. 182/2025, 108/2025, 73/2025 and 21/2025. Certain goods have phased tax increases, such as yellow phosphorus from 5% to 10% in 2026 and 15% in 2027; black corrugated iron at 0% until August 2025 and 7% from September 2025. |
| Coordination with VAT | Some tax exemptions overlapped with VAT exemptions or non-taxable items. | The scope is clarified to avoid situations where the same goods are exempt from both export-import duty and VAT. |
Business implication: Enterprises should review import duty incentives, VAT exemption treatment, refund documentation and investment project refund conditions to ensure compliance with the updated framework.
02
Official Letter No. 434/VLO-QLDN2
On 21 August 2025, the Vinh Long Provincial Tax Department issued Official Letter No. 434/VLO-QLDN2 in response to a query from Duyen Hai Thermal Power Company, a branch of Power Generation Corporation 1, regarding input VAT deduction for goods and services purchased on deferred or installment payment terms under Decree No. 181/2025/ND-CP dated 1 July 2025.
Key guidance
Under Clause 2, Article 26 of Decree No. 181/2025/ND-CP, for goods and services purchased on deferred or installment payment terms with a value of VND 5 million or more, the business must have non-cash payment documents at the time of payment as specified in the contract or contract addendum in order to deduct input VAT.
Input VAT deduction requirement
Non-cash payment documents are required at the payment date stated in the contract or contract addendum for purchases valued at VND 5 million or more.
Adjustment obligation
If the business does not have valid non-cash payment documents at the required time, it must declare and adjust to reduce the input VAT amount already deducted for the value without supporting payment documents.
Important note: The business cannot continue deducting VAT for the portion of goods or services without valid non-cash payment documents.
03
Official Letter No. 95/BNI-QLDN1
On 22 July 2025, the Bac Ninh Provincial Tax Department issued Official Letter No. 915/BNI-QLDN1 in response to Samsung Electronics Vietnam Co., Ltd. regarding the personal income tax treatment of mid-shift meal expenses.
Key personal income tax treatment
- If the business organizes mid-shift meals, such as cooking meals or purchasing meal portions, the expense is not included in the employee’s taxable personal income.
- If the business does not organize meals but provides a cash allowance to employees, the allowance is not included in taxable personal income if the amount is consistent with the labor contract, collective labor agreement or company regulations.
- If the cash allowance exceeds the applicable internal or agreed limit, the excess amount must be included in taxable personal income.
Key change: According to the guidance in Official Letter No. 915/BNI-QLDN1 in 2025, the fixed mid-shift meal allowance limit of VND 730,000 per month has been abolished. Businesses may determine a reasonable allowance level based on the collective labor agreement, internal labor regulations or company policies.
Download the Full Newsletter
Download the complete PDF version of the JPA Vietnam Tax & Legal Newsletter – September 2025 for offline reading, internal sharing and future reference.
Need professional tax advice in Vietnam?
JPA Vietnam supports multinational corporations, foreign-invested enterprises and local businesses with practical tax advisory, accounting, audit and compliance solutions tailored to Vietnam’s evolving regulatory environment.
Our Services
Audit and Assurance
Accounting and Financial Reporting (VAS and IFRS)
Tax Compliance and Advisory
Financial and Tax Due Diligence (FTDD)
Payroll Services
Transfer Pricing Services
Contact JPA Vietnam
Ho Chi Minh Office
No. 06 – 07, Phan Ton Street, Tan Dinh Ward, Ho Chi Minh City, Vietnam
Phone: +84 28 2245 8787
Email: clientcare@jpa.vn
Website: www.jpa.vn
This newsletter is for general information purposes only and should not be considered professional advice for any specific case.
TÓM TẮT BÀI VIẾT VỚI AI:
