The corporate income tax (CIT) management policy has undergone significant adjustments regarding the method of paying salaries and wages. According to the new guidelines, from December 15, 2025, businesses will no longer be allowed to account for salary expenses of 5 million VND or more per payment if paid in cash. Instead, these expenses must be paid through non-cash methods to be considered reasonable expenses when determining taxable income.
The above content has been clarified by the Ministry of Finance in Official Letter No. 218/CST-TN dated January 27, 2026, thereby unifying the understanding and practical application.
Legal basis for regulating wage costs
The current recognition of salary and wage expenses is governed by the following legal framework:
- Corporate Income Tax Law No. 67/2025/QH15
- Decree No. 320/2025/ND-CP
According to the guidelines in Official Letter 218/CST-TN, a salary payment can only be included as a deductible expense if it simultaneously meets all of the following conditions:
- The expenditure is directly related to the business operations of the enterprise.
- All required documents and records are available, including: employment contracts, payroll records, and payment documents.
- Not included in the group of expenditures excluded under Clause 8, Article 10 of Decree 320/2025/ND-CP.
- Businesses must have actually made the payment and possess valid payment documentation; cases where expenses are only recorded in the books but not actually paid or lack valid documentation will not be accepted.
New regulations on cashless payment for salaries.
The key change from the end of 2025 is the establishment of a separate threshold for cashless payments of salaries and wages. Compared to before, the new regulations are more specific and stringent:
- Prior to December 15, 2025, the law did not specifically stipulate a threshold for salary payments; in practice, a threshold of 20 million VND was commonly applied to invoices for goods and services.
- From December 15, 2025, all salary and wage payments to employees with a value of 5 million VND or more per payment must be made via bank transfer.
This regulation applies based on the "value of each payment," regardless of total monthly income. Therefore, if the combined salary, bonus, or allowances amount to 5 million VND or more in a single payment, the company is required to make the payment through a bank.
What constitutes a valid non-cash payment document?
To avoid having expenses disallowed during a tax audit, business accountants need to correctly identify the legal form of payment as follows:
- Decree No. 52/2024/ND-CP
- Article 26 of Decree No. 181/2025/ND-CP
Accordingly, valid non-cash payment documents include:
- The order is to transfer funds from the company's account to the employee's account.
- Other electronic payment methods permitted by law are available, provided the transaction is clearly documented through the banking system or credit institution.
Important Note: Businesses that deposit cash directly into employees' accounts are still considered to be making cash payments. In this case, if the payment is 5 million VND or more per transaction, the payment will not be considered a deductible expense.
Recommendations for businesses when paying salaries and wages.
To mitigate tax risks and ensure compliance with new regulations, businesses should proactively implement the following measures:
- Collect bank account information for all employees, including seasonal workers and freelancers, whose income is 5 million VND or more per transaction.
- Strictly control small, incidental expenses: if the total amount in a single payment reaches 5 million VND, absolutely no cash payments should be made.
- Keep complete records of documents: bank statements, payment orders, payroll records, etc., to facilitate tax audits and inspections.
Strict adherence to the new regulations not only helps businesses protect their rights regarding corporate income tax expenses, but also contributes to the policy of transparency in cash flow and transactions within the economy.
Contact information MAN – Master Accountant Network
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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.
Source: Article by LuatVietnam
MAN Editorial Board – Master Accountant Network
