Confusion between "work" and "money
Mr. N.M.K - a business owner of medical services who has only been operating for 02 months - expressed concern about many new tax policies in 2026.
With an estimated revenue of 500 million to under 3 billion VND/year, Mr. K.'s establishment will have to switch to tax payment by declaration method. However, his service characteristics include both service fees and raw material costs (drugs/vaccines). This makes determining tax obligations complicated.
I am very confused whether my service is exempt from VAT or not? If it is exempted, will it be applied to all invoices or only exempt from service fees, and the medicine money still has to be taxed?", Mr. K. wondered about the fragile boundary between tax rates.
The secret lies in the "Service Package
To answer this question, Basic Tax No. 3 (Dong Nai province) has detailed guidance based on the Value Added Tax Law No. 48/2024/QH15. The answer opens up an interesting tax calculation "mechanism" depending on the product package structure.
Medical services (including medical examination and treatment, vaccination, disease prevention...) are not subject to VAT (exempt from output tax).
However, for the money for accompanying medicines/vaccines, the tax rate will change depending on the case:
TAX-FREE (Tax-free): If the revenue from medicines/vaccines is fully included in the disease treatment/vaccination service package according to the regulations of the Ministry of Health (including both medicines and public funds).
Must be subject to 5% tax: If the treatment service package does not include medicine (medicines are separated and sold separately, prescribed separately).
Thus, the difference can be understood in the construction of a service package. If a medical facility provides a full-package service (medicine is included in the service price), all revenue will not be subject to VAT. Conversely, if the drug fee is separated from the medical examination and treatment fee, the drug fee will be subject to a preferential tax rate of 5%.
This is the key point that business households in the fields of healthcare and healthcare need to pay attention to when setting prices and issuing invoices from 2026 to optimize tax obligations in accordance with the law.
