30% CIT reduction for 2026 and 2027: which businesses qualify and what to watch

Updated 13 October 2026. Businesses with annual revenue of no more than VND 10 billion get a 30% reduction in the corporate income tax (CIT) payable for 2026 and 2027. This is set out in Resolution No. 43/2026/QH16, in force from 24 August 2026.

The policy clearly benefits small businesses. Even so, there are three points to understand before the year-end tax finalisation: how revenue is determined, how the reduction works for businesses already receiving tax incentives, and the anti-splitting rule that stops businesses getting under the threshold artificially. This article follows the text passed by the National Assembly and gives the current status of the implementing decree.

Legal basis and status of guidance

The direct legal basis for the reduction is Resolution No. 43/2026/QH16. As of 13 October 2026, the implementing decree had not been issued. To work out how much a business actually pays, read Resolution 43 together with the current rules on tax rates and the exemption threshold.

This article covers CIT only. The 30% reduction in personal income tax for household and individual businesses under the same Resolution will be covered by FC Legal in a separate article.

Which businesses qualify?

Under Clause 2, Article 1 of Resolution 43, a business must meet both conditions:

• It is an enterprise or organisation established under Vietnamese law.
• Its annual revenue for 2026 or 2027 is no more than VND 10 billion.

The Resolution uses the words “no more than”, so revenue of exactly VND 10 billion still qualifies.

Points awaiting the implementing decree

The Resolution does not yet set out the following points in detail. Wait for the implementing decree before finalising your tax figures:

• Which revenue figure is used to test the VND 10 billion threshold (total revenue on the finalisation return, and whether financial income and other income are included).
• How revenue is annualised for newly established businesses or those operating for less than 12 months in the year.
• Whether the threshold is tested separately for each year. The Resolution refers to revenue “of 2026, of 2027”, so the common reading is that each year is tested separately. For example, with revenue of VND 9 billion in 2026 and VND 12 billion in 2027, the reduction applies for 2026 but not for 2027. This reading needs to be confirmed by the decree.

Which group is your business in?

Find your group in the table below. Businesses with revenue of VND 1 billion or less are already exempt from CIT, so they do not need the 30% reduction.

The effective rate is the tax rate multiplied by 70% (15% × 70% = 10.5%; 17% × 70% = 11.9%), for businesses with no other incentives. The table is simplified: the tax rate is based on the previous year’s revenue, while the exemption threshold and the VND 10 billion threshold may be tested against different reference points, as explained above.

How to calculate the reduction

The reduction is 30% of the CIT payable. It is not 30% of the tax rate or 30% of income. If the business already receives a tax incentive, the 30% reduction is calculated on the tax still payable after the incentive.

Illustrative example (revenue, income and incentive figures are assumed; tax rates under Article 10 of the CIT Law 2025):

Legal basis: second paragraph, Clause 2, Article 1 of Resolution No. 43/2026/QH16.

According to press reports, the draft implementing decree proposes calculating the reduction on all of the business’s income, regardless of the tax calculation method. This is not yet law and will be updated when the decree is issued.

Splitting a business to get the reduction: not accepted

A business formed by a split or separation after 24 August 2026 does not get the reduction if the combined revenue of the businesses after the split exceeds VND 10 billion. This rule is in Clause 2, Article 1 of Resolution 43 itself.

Example: Company X has revenue of about VND 16 billion a year. In October 2026, X splits into two companies, each with revenue of about VND 8 billion. Combined revenue after the split is still VND 16 billion, which is over VND 10 billion. So neither new company gets the reduction, even though each is below the threshold.

Points to note:

• The rule only applies to splits and separations after 24 August 2026. Businesses that split before then are not caught by this exclusion.
• The Resolution only refers to a “split or separation of an enterprise”. It does not mention setting up a new company to move revenue across gradually, or other forms of restructuring. However, Article 11 of Decree No. 320/2025/ND-CP (guiding the CIT Law 2025) does not allow the 15% and 17% rates for a subsidiary or affiliated company if a company in the affiliated relationship does not meet the conditions. Get advice before restructuring.

Procedure and risks at year-end finalisation

Resolution 43 does not set out a filing procedure. This will be set by the implementing decree. Businesses should not apply the reduction themselves before there is official guidance on the forms and the revenue figure to use.

Three risks to prepare for now:

• Misjudging revenue when paying provisional tax. A business with revenue close to VND 10 billion may apply the reduction provisionally, then find at year end that actual revenue is over the threshold. It may then have to pay the tax it had provisionally reduced. Track cumulative revenue every quarter.
• Recording revenue in the wrong period. Delaying invoices or pushing revenue recognition into the next year to stay under the threshold may be adjusted by the tax authority on inspection.
• Records supporting tax incentives. Businesses receiving tax incentives need complete incentive records, because the 30% reduction is calculated after the incentive.

The specific consequences (back tax, late payment interest, penalties) will depend on the implementing decree and the current tax administration rules.

Frequently asked questions

Which years does the 30% CIT reduction apply to?

The 2026 and 2027 tax periods (Clause 1, Article 2 of Resolution No. 43/2026/QH16).

Does a business with revenue of exactly VND 10 billion qualify?

Yes. The Resolution refers to revenue of “no more than VND 10 billion”.

Can a business already exempt or receiving reductions under investment incentives get a further reduction?

Yes. The 30% reduction is calculated on the tax still payable after the incentive. If the business is in a period of full tax exemption, there is no tax payable left to reduce.

Do foreign-invested businesses qualify?

Resolution 43 applies to enterprises and organisations “established under Vietnamese law” and has no clause excluding foreign-invested businesses. For a similar policy, the incentives for small and medium-sized enterprises under Resolution No. 198/2025/QH15, some local tax authorities had issued guidance excluding FDI businesses. However, the Tax Department later confirmed in Official Letter No. 3896/CT-CS dated 11 June 2026 that foreign ownership is not a ground for exclusion. So FDI businesses established in Vietnam have a basis to claim the reduction under Resolution 43, but should check the implementing decree once it is issued.

What about businesses with revenue below VND 1 billion?

Businesses and organisations with total annual revenue of VND 1 billion or less are exempt from CIT under Clause 14a, Article 4 of the CIT Law (added by Law No. 09/2026/QH16) and Decree No. 320/2025/ND-CP as amended by Decree No. 141/2026/ND-CP. So this group does not need the 30% reduction.

Has the implementing decree been issued?

As of 13 October 2026, the decree had not been issued. The Ministry of Finance has consulted on a draft, and the Prime Minister has instructed that it be submitted to the Government for issuance immediately.

See also: Proactive compliance in 2026: what businesses need to do as tax, personal data and employment law change together (available in Vietnamese).