Official document No. 3987/QNG-NVDTPC on corporate income tax policy is an important guidance document that helps businesses understand and correctly apply the new regulations in Decree 320/2025/ND-CP when fulfilling their corporate income tax obligations. This article focuses on a comprehensive analysis of the prominent updates such as taxpayers, tax-exempt income, conditions for deductible expenses, regulations on cashless payments, and applicable tax rates, thereby helping businesses, accountants, and managers proactively comply, minimize risks, and optimize tax management efficiency in the period of 2026.
Legal basis of Official Letter No. 3987/QNG-NVDTPC on corporate income tax policy
To fully understand the content and application of Official Letter No. 3987/QNG-NVDTPC on corporate income tax policy, it is first necessary to clarify the legal basis for the formation of this document, including the core regulations in Decree 320/2025/ND-CP and the guiding role of local tax authorities in its implementation.
Decree 320/2025/ND-CP – The core legal foundation
Prior to the effective date of Decree 320/2025, corporate income tax policies were primarily applied according to older guiding decrees (typically Decree 218/2013/ND-CP and its amendments and supplements).
Some limitations of the old regulations include:
- The concept of taxpayers has not kept pace with the development of the digital economy, especially for foreign businesses operating across borders.
- The list of tax-exempt income categories is still narrow and does not accurately reflect the role of businesses in agriculture, environment, and disaster prevention.
- The conditions for deductible expenses lack a clear threshold for cashless payments, leading to inconsistent interpretations and applications across localities.
- Preferential tax rates have not been flexibly tiered according to business size.
These points highlight the need for a new decree that is more consistent and aligned with the Corporate Income Tax Law of 2025.
Decree 320/2025/ND-CP, issued on December 15, 2025, applies to corporate income tax periods from 2025 onwards. It aims to provide detailed guidance on the implementation of the Corporate Income Tax Law No. 67/2025/QH15, replacing and updating many previous regulations that are no longer suitable for the new business environment, especially e-commerce and the digital economy.
The key contents of Decree 320/2025/ND-CP include:
- To more clearly identify corporate income tax payers;
- Additional tax-exempt income;
- Tighten the conditions for deductible expenses;
- Specific tax rates are stipulated for each group of businesses.
Based on Decree 320/2025/ND-CP, which established a complete legal framework for the implementation of the Corporate Income Tax Law, correctly understanding and consistently applying the new regulations in practice remains a challenge for many businesses. Therefore, Official Letter No. 3987/QNG-NVDTPC on corporate income tax policy was issued to clarify the core content, guide the understanding and specific implementation of the new points of Decree 320/2025, helping businesses mitigate risks and comply with tax laws.
The role of Official Letter No. 3987/QNG-NVDTPC on corporate income tax policy.
Based on Decree 320/2025, Official Letter No. 3987/QNG-NVDTPC issued on December 29, 2025, regarding corporate income tax policy by the Quang Ngai Provincial Tax Department plays the following role:
- Systematizing the key new points
- Explain the understanding and practical application.
- Minimize the risk of errors when filing and settling corporate income tax.
This is why Official Letter No. 3987/QNG-NVDTPC on corporate income tax policy is considered a reliable reference document for businesses in 2026.
Summary of key new points according to Official Letter No. 3987/QNG-NVDTPC on corporate income tax policy.
Based on the detailed guidance in Official Letter No. 3987/QNG-NVDTPC regarding corporate income tax policy, many important contents of Decree 320/2025/ND-CP have been clarified and updated, directly impacting the determination of tax obligations for businesses. Below is a summary of the prominent new points that businesses, accountants, and financial managers need to pay special attention to in order to apply correctly and minimize risks during implementation.
Clarifying the subjects liable for corporate income tax.
One of the most important points in Official Letter No. 3987/QNG-NVDTPC regarding corporate income tax policy is the clarification of the concept of corporate income tax payers, especially for foreign enterprises.
According to the new guidelines:
- Foreign businesses with a permanent establishment in Vietnam must pay corporate income tax on all related income.
- Businesses that do not have a permanent establishment but generate income in Vietnam are still subject to taxation.
- Business activities conducted through digital platforms and e-commerce are subject to stricter regulation.
This regulation helps to reduce tax revenue losses and ensure fairness between domestic and cross-border businesses.
Adding tax-exempt income items.
According to Official Letter No. 3987/QNG-NVDTPC on corporate income tax policy, Decree 320/2025 has expanded the scope of tax-exempt income, notably including:
- Several types of income from providing technical services directly serving agriculture are exempt from tax, including: Income from services related to flood control, flood prevention, tidal surge prevention, salinity control, salt leaching, acid leaching, and freshwater retention.
- The guidelines for identifying the aforementioned technical services are based on the first-level economic sector code of the agricultural sector as stipulated in the Vietnamese Economic Sector Classification System.
This addition reflects a supportive tax policy direction, encouraging businesses to participate in essential sectors and contribute to sustainable development.
Conditions for cashless payments: Notable tightening points
One new point directly impacting accounting practices, highlighted in Official Letter No. 3987/QNG-NVDTPC regarding corporate income tax policy, is that expenses of 5 million VND or more are only deductible when supported by non-cash payment documents.
- In cases where a business makes multiple purchases of goods or services on the same day from the same seller, even if each payment is less than 5 million VND, if the total value of the transactions reaches 5 million VND or more, this expense will only be accepted as a deductible expense when determining taxable income if there is complete non-cash payment documentation.
- In cases where the enterprise authorizes the employee to make purchases on its behalf: When the enterprise assigns or authorizes the employee to directly purchase goods and services for production and business activities, expenses valued at 5 million VND or more are still considered deductible expenses if the employee pays using non-cash methods and the expense fully meets the conditions stipulated by tax law.
This regulation requires businesses to:
- Strictly control payment methods.
- Keep complete records of the bank transfers.
- Synchronizing electronic invoices with real-world cash flow.
If compliance is not met, expenses, even with legitimate invoices, risk being disallowed during corporate income tax settlement.
Identify and transfer holes according to the new guidelines.
Official document No. 3987/QNG-NVDTPC on corporate income tax policy continues to affirm the principle:
- Businesses are allowed to carry forward losses for a maximum of 5 consecutive years.
- Losses must be accurately determined for each tax period.
- Losses cannot be carried forward to previous years.
The new feature lies in providing clear guidance on how to determine losses in cases where businesses have multiple different production and business activities.
Corporate income tax rates according to Decree 320/2025/ND-CP
According to the information summarized in Official Letter No. 3987/QNG-NVDTPC regarding corporate income tax policy, the corporate income tax rates are applied as follows:
- 20%: General Tax Rate
- 15% or 17%: Applicable to small and medium-sized enterprises with specific revenue requirements.
- Separate tax rates for the oil and gas and resource extraction industries.
Tax tiering allows for greater flexibility in tax policies and makes them more suitable for different groups of businesses.
Impact of Official Letter No. 3987/QNG-NVDTPC on corporate income tax policy for businesses
The implementation of Official Letter No. 3987/QNG-NVDTPC on corporate income tax policy presents both opportunities and challenges:
Benefit:
- Reduce legal risks by applying regulations correctly;
- Optimizing legal tax obligations;
- Improve financial transparency.
Challenge:
- Increased demands for document management;
- Compliance pressure on small businesses;
- New policies need to be updated promptly.
From the above analysis, it can be seen that the regulations regarding deductible expenses when businesses authorize employees to make purchases on their behalf have been clarified in a way that is both stricter and more flexible. The requirement for cashless payments for expenses of 5 million VND or more aims to increase transparency, control cash flow, and limit tax risks for businesses. At the same time, this regulation also creates a clear legal basis for businesses to proactively develop purchasing, payment, and document storage processes in accordance with current regulations.
Conclude
It can be affirmed that Official Letter No. 3987/QNG-NVDTPC on corporate income tax policy is a highly practical guidance document, helping businesses understand and correctly apply the new regulations of Decree 320/2025.
In the context of increasingly stringent and transparent tax policies, proactively researching and complying with Circular No. 3987/QNG-NVDTPC on corporate income tax policy will not only help businesses mitigate risks but also create a solid foundation for sustainable development in 2026 and beyond.
Contact MAN – Master Accountant Network for support and advice on the latest tax policy updates.
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Content production by: Mr. Le Hoang Tuyen – Founder & CEO MAN – Master Accountant Network, Vietnamese CPA Auditor with over 30 years of experience in Accounting, Auditing and Financial Consulting.
Frequently Asked Questions about Official document No. 3987/QNG-NVDTPC regarding corporate income tax policy.
Are payments of 5 million VND or more required to be made using non-cash methods in all cases?
Yes. According to the new regulations, expenses of 5 million VND or more are only deductible if there is non-cash payment documentation, including cases where the company authorizes employees to make purchases on their behalf. Cash payments will create the risk of expenses being disallowed during corporate income tax settlement.
Is it acceptable for employees to receive payments via their personal bank accounts?
Acceptable, provided the business has written authorization or assignment to purchase on behalf of the employee, the employee pays using a non-cash method, and the business has complete documentation of reimbursement, legal invoices, and related payment documents. If any of these elements are missing, the expense may not be deductible.
Do the new regulations apply to all businesses or only large ones?
Regulations on cashless payments and deductible expenses apply to all types of businesses, regardless of size. Small and medium-sized enterprises (SMEs), if they have not yet standardized their accounting and payment processes, will be the group most significantly affected.
MAN Editorial Board – Master Accountant Network
