Summary of new points in Circular 20/2026/TT-BTC

The legal framework for corporate income tax has just undergone a major turning point with the issuance of regulations by the Minister of Finance. Circular 20/2026/TT-BTCThis is considered the successor document replacing older guidance documents such as Circular 78/2014/TT-BTC and Circular 96/2015/TT-BTC. For tax accountants, understanding the new points in Circular 20/2026/TT-BTC is not only a mandatory requirement for compliance but also key to optimizing costs and managing business risks. To ensure absolute accuracy during this transition period, many businesses have chosen to implement these new guidelines. full accounting service Professional and experienced in keeping up-to-date with legal changes.

New points in Circular 20/2026/TT-BTC stipulate stricter requirements for documentation of deductible expenses.

The majority of the content in Article 3 of Circular 20/2026/TT-BTC specifies the necessary types of documents. Compared to the old regulations, the current document requirements have been significantly more detailed and stringent.

Expenditure on vocational training and education

Accountants should note that, for training expenses to be recognized as legitimate costs, the documentation must ensure consistency between:

• The employment contract or financial regulations clearly stipulate the expenditure for training.
• Decision to send for study and application documents.

Specifically: Employees must provide diplomas, certificates, or documents confirming their academic achievements.

Records of grant expenditures

For educational, medical, and disaster relief donations, a new provision in Circular 20/2026/TT-BTC mandates that businesses must use Form No. 01/TNDN (Confirmation of Donation) issued with this Circular. Without this form, the expenditure risks being disallowed during final accounting.

Specific expenses that do not correspond to revenue during the period.

This is a crucial step in resolving accounting issues. The circular allows for the inclusion of the following cases as deductible expenses:

• Bidding costs: Including costs even if the bid is not won (requires tender documents, bid submissions, and contractor selection results).
• Market research or product development: In case of failure or discontinuation, the accountant must also prepare a report as required. Decree 320/2025/ND-CP.
• Leased assets that are not currently occupied: Depreciation is permitted if sufficient ownership and accounting records are available.
• Pre-operating expenses: Costs of establishment, pre-sales marketing, dissolution, or restoration of the status quo.
• Destruction of inventory or assets: Requires thorough documentation including the Destruction Decision, Inventory Report (clearly stating the reason, quantity, and value), and the Disposal Committee's Decision.

Greenhouse gas emission reduction cost profile

For the first time, expenses related to reducing greenhouse gas emissions and carbon neutrality to protect the environment are clearly defined. The condition for accounting to include these expenses is that the enterprise must have a specific plan or project and an implementation decision from an authorized person.

The mechanism allows for employee authorization to process payments starting from 5 million VND.

This is a crucial accounting detail for controlling cash flow during purchasing transactions. When authorizing employees to make cashless payments for goods worth 5 million VND or more, the documentation must include four types of records:

• Legitimate invoices and documents.
• The internal financial regulations govern the delegation of authority.
• Non-cash payment vouchers issued by employees to vendors.
• The company's payment documents are sent to the employee via bank transfer.

Under these conditions, there was Official Document 5082/BTC-CST Provide direct answers regarding cashless payment terms and clarify instructions on how to authorize payment. 

New points in Circular 20/2026/TT-BTC change the time of revenue determination.

Determining the correct period for calculating revenue tax is a key task for accountants to avoid penalties for late payment or tax arrears. Circular 20/2026/TT-BTC clarifies this point:

• Export date: This is the date of transfer of ownership according to the contract. If the contract does not specify, the date of export of goods as determined by customs law shall be used.
• Air freight: The time of completion of the transportation service.
• Construction and installation (including shipbuilding): Time of acceptance and handover (regardless of whether payment has been received or not).
• Electricity and water supply: Date of meter reading confirmation as recorded on the bill.

Adding a timeframe for revenue recognition for foreign businesses:

• Capital transfer: The time of transfer of ownership.
• Transfer of securities and certificates of deposit: Time of transfer.
• Derivative securities (futures contracts): The time of order execution or expiration.

Tax obligations of foreign businesses

Circular 20/2026/TT-BTC has systematized and supplemented the legal framework for modern business activities:

• E-commerce and Digital Platforms: Foreign businesses operating on digital platforms in Vietnam (with or without a permanent establishment) are subject to corporate income tax.
• Internal restructuring: Transactions within the group that do not change the ultimate parent company and do not generate income (ensuring book value) may be exempt from tax.
• Tax calculation principle: If the contract does not clearly separate the value of the activities, the tax authorities will apply the highest % rate to the entire contract value.

Management of expansion investment capital and the Science and Technology Fund

One new point in Circular 20/2026/TT-BTC that accountants in manufacturing companies need to pay attention to is the obligation to notify capital:

• Investment capital for expansion: Businesses must notify the tax authorities in writing of the registered capital for the expansion project at the same time as submitting the Corporate Income Tax Return.
• Assets from the Science and Technology Fund: If assets are transferred from the Science and Technology Fund to serve production and business activities before their depreciation is fully exhausted, the remaining value must be included in other income, but at the same time, the accountant is allowed to depreciate this value as a deductible expense.

These complex tasks require tight control and are new to inexperienced accountants, therefore the best solution the business should consider is... hire chief accountant They are part of the MAN – Master Accountant Network because they receive continuous training and updates. They also have a team of tax experts behind them, ready to provide support and explanations when needed.

Effective date and transitional provisions for accounting

Circular 20/2026/TT-BTC takes effect from March 12, 2026 and applies to the 2025 tax year. Accountants should note the following transitional dates:

• For the 2025 tax year: Expenses incurred before the Circular came into effect and already regulated by Circular 96/2015 will continue to be governed by Circular 96. New expenses (such as depreciation of leased assets without tenants) will follow the documentation prescribed in Circular 20.
• Regarding non-cash payment documents: New regulations will apply from December 15, 2025, according to Decree 320/2025/ND-CP.
• Repealed documents: Completely replace Circular 78/2014/TT-BTC and Circular 96/2015/TT-BTC.

Here is an updated list of repealed regulations for accountants to refer to:

• Regulations in Circular 103/2014/TT-BTC (on contractor tax).
• Article 6 of Circular 119/2014/TT-BTC.
• Chapter I of Circular 151/2014/TT-BTC.
• Article 5 of Circular 130/2016/TT-BTC.
• Article 3 of Circular 25/2018/TT-BTC.
• Regulations on the Science and Technology Fund are stipulated in Circular 67/2022/TT-BTC.

Conclude

The new provisions in Circular 20/2026/TT-BTC reflect a trend towards increased transparency and stricter documentation requirements by tax authorities. For corporate accountants, reviewing internal financial regulations and document archiving procedures now is crucial to adapt to the major legal changes expected in 2026.

In the context of constantly changing regulations, businesses may consider the following solutions. hire an accountant to prepare financial statements. To ensure that all figures during the settlement process strictly comply with the latest regulations.

For any questions, support, advice, or clarification, please contact MAN – Master Accountant Network:

 

Contact information MAN – Master Accountant Network

• Address: No. 19A, Street 43, Tan Thuan Ward, Ho Chi Minh City
• Mobile/Zalo: 0903 963 163 – 0903 428 622
• Email: man@man.net.vn

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 the New Points in Circular 20/2026/TT-BTC

Which tax periods does Circular 20/2026/TT-BTC apply to?

The regulations apply immediately to the 2025 tax year. Regarding regulations on capital transfers and non-cash documents, accountants should note the effective date of December 15, 2025, as stipulated in Decree 320/2025/ND-CP to ensure the legality of the actual documentation.

What additional documents are required for employee training expense records according to the new regulations?

In addition to employment contracts and training assignment decisions, a new requirement in Circular 20/2026/TT-BTC mandates the submission of diplomas, certificates, or confirmations of academic achievements for employees. Accountants need to review financial regulations to ensure these expenses are clearly defined and to avoid the risk of being disallowed.

How can the costs of funding education and healthcare be considered reasonable expenses?

For grants to be accepted as deductible expenses, accountants are required to use Form No. 01/TNDN (Minutes of Grant Confirmation) issued with Circular 20/2026/TT-BTC. Self-prepared forms or those based on old regulations will no longer be valid, leading to the risk of the expenses being disallowed by the tax authorities during tax settlement.

Have there been any changes to the timing of determining taxable revenue for exported goods?

According to the new provisions of Circular 20/2026/TT-BTC, export revenue is determined on the date of transfer of ownership as stipulated in the contract. If the contract does not specify this date, accounting must base it on the date of export as determined by customs law. This helps to synchronize data between tax and customs authorities.

What documentation does a business need to prepare for emissions reduction expenses?

This is a significant new provision, introduced for the first time. Businesses wishing to include greenhouse gas emission reduction and carbon neutrality costs as deductible expenses must have a specific plan or project approved by the competent authority. Accountants need to maintain complete project documentation along with actual supporting documents for explanation.