Revises rules on permanent establishment and removes certain tax incentives
14 Jun 2025
On 14 June 2025, Viet Nam enacted Law No. 67/2025/QH15 on Corporate Income Tax (CIT), revising the definition of permanent establishment (PE) for foreign enterprises, and the incentive regime. The new law extends the definition of PE to include e-commerce and digital platforms and requires foreign enterprises with a PE in Viet Nam to pay CIT on all income generated domestically, as well as certain foreign sourced income related to the PE’s operations. Foreign enterprises without a PE remain subject to CIT only on income arising in Viet Nam.
The law also abolishes CIT incentives for large-scale investment projects with total capital of VND (Vietnamese Dong) 6,000 billion ($236 million) or more and for projects located in industrial parks. The law will enter into force on 1 October 2025 and apply from the 2025 tax year.
Nature of measure:
Type:
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Treatment and operation (Other)
Industry:
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Not industry specific
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Services (Wholesale and retail trade, Publishing, audiovisual and broadcasting activities, Computer programming, consultancy and related activities)
Inward FDI:
Yes
Outward FDI:
No
Sources:
