Decree 320/2025/ND-CP guiding the Law on Corporate Income Tax, effective from December 15, 2025 and applied from the 2025 corporate income tax calculation period. The determination of application time in some specific cases is as follows:
- Enterprises are selected to apply regulations on revenue, expenses, tax incentives, tax exemptions, tax reduction, loss transfer in this Decree from the beginning of the 2025 tax calculation period or from the date the Enterprise Income Tax Law takes effect or from the date this Decree takes effect; in case the 2025 tax calculation period of enterprises starts after the date the Enterprise Income Tax Law takes effect, it is applied from the date the Enterprise Income Tax Law takes effect or from the date this Decree takes effect;
- 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.
Regarding the issue of salaries over 05 million VND that must be transferred to be deducted from tax calculation costs:
Clause 1, Article 9 of Decree 320/2025/ND-CP dated December 15, 2025 (applied 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 Corporate Income Tax Law stipulates:
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:
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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".
Based on the above regulations, in case the enterprise pays employees of the enterprise a salary of 05 million VND or more each time without payment vouchers in cash as prescribed, it is not included in the deductible expenses when determining corporate income taxable income.
Thus, the time when salaries over 05 million VND must be transferred to be deducted from corporate income tax calculation expenses are expenses from December 15, 2025.
