At the Dialogue Conference between the Ministry of Finance and taxpayers on tax policies, administrative procedures and customs in 2025 organized by the Ministry of Finance in coordination with the Vietnam Federation of Commerce and Industry (VCCI) on the morning of December 26, Quang Tri Trading Corporation (headquartered in Dong Ha, Quang Tri) raised questions related to regulations on deductible expenses when determining income subject to corporate income tax.
According to the business representative, based on Decree No. 320/2025/ND-CP dated December 15, 2025, detailing and guiding the implementation of a number of articles of the Law on Corporate Income Tax, at Point c, Clause 1, Article 9, it is stipulated that: The payment amount has non-cash payment documents for the purchase of goods, services and other payments each time with a value of VND 5 million or more. Documents for non-cash payment are implemented in accordance with the provisions of the law on value added tax.
From this regulation, the enterprise asked: In case of paying wages to employees in cash or in kind, with a payment of over 5 million VND/person/time, will this payment be included in the expenses deducted when determining taxable income?
Responding to the above issue, the Organizing Committee of the Conference said that Clause 1, Article 9 of Decree No. 320/2025/ND-CP dated December 15, 2025 (applicable from the 2025 corporate income tax calculation period) of the Government detailing a number of articles and measures to organize and guide the implementation of the Law on Corporate Income Tax stipulates:
Article 9. Expenditures deducted when determining taxable income
1. Except for the expenditures not deducted as prescribed in Article 10 of this Decree, enterprises are allowed to deduct expenditures when determining taxable income if they meet the conditions in points a, b and c below:
...
c) Expenditures with non-cash payment documents in cases of purchase of goods, services and other payments each time with a value of VND 05 million or more. Cashless payment documents are implemented according to the provisions of legal documents on value added tax".
Pursuant to the above provisions, in case the enterprise pays the salary to the enterprise's employees at least VND 05 million each time without having non-cash payment documents as prescribed, it will not be included in the expenses except for determining the income subject to corporate income tax.
