On December 30, 2025, Bac Ninh Provincial Tax Department received Official Dispatch No. 01/2025/CV-FCVN dated December 30, 2025 from Faco Vietnam Financial and Audit Consulting Co., Ltd. (hereinafter referred to as the Company) asking about the content of non-cash payments for salaries and wages paid in cash when determining costs deducted from corporate income tax.
Regarding this issue, Bac Ninh Provincial Tax Department has the following opinions:
Based on Decree No. 320/2025/ND-CP dated December 15, 2025 of the Government detailing:
- Point c, Clause 1, Article 9 stipulates the deductible expenses when determining taxable income
Article 9. Deductible expenses when determining taxable income
1. Except for non-deductible expenses specified in Article 10 of this Decree, enterprises are entitled to deduct expenses when determining taxable income if they meet the conditions in points a, b and c below:
c) Expenditures with non-cash payment vouchers for purchases of goods, services and other payments each time with a value of 05 million VND or more. Non-cash payment vouchers are made in accordance with the provisions of legal documents on value-added tax..”.
- Point b, Clause 1, Article 24 stipulates the effectiveness of the law
Article 24. Effectiveness of enforcement
1. This Decree takes effect from the date of signing and promulgation and applies from the 2025 corporate income tax calculation period. The determination of the application period in some specific cases is as follows:
b) Regulations on non-cash payment vouchers at point c, clause 1, Article 9 and regulations on capital transfer at point i, clause 3, Article 12 of this Decree apply from the date this Decree takes effect".
Based on the above-mentioned guiding regulations and the content of the Company's question, Bac Ninh Provincial Tax Department said:
In case the company pays salaries (collectively referred to as other payments) to employees of the enterprise from 05 million VND or more each time without cashless payment vouchers as prescribed, they are not included in the deductible expenses when determining corporate income taxable income. This regulation is applied from the time Decree 320/2025/ND-CP dated December 15, 2025 takes effect.
