Businesses "shocked" by regulations on non-cash payments
Mr. N.V.C expressed confusion when approaching Decree No. 320/2025/ND-CP just issued at the end of 2025. Specifically, point c, clause 1, Article 9 of this Decree stipulates that expenses worth 5 million VND or more must have non-cash payment vouchers to be included in valid expenses.
As the drafting agency, please clarify: Are salary and wage expenses paid each time from 5 million VND or more required to be transferred or use other non-cash forms to be calculated as deductible expenses when determining corporate income taxable income?" - Mr. C. raised the issue. This is also a common concern of many units that still maintain the habit of paying salaries directly in cash to employees.
Warning about removing costs when the payment form is incorrect
To answer this question, the Quang Tri Provincial Tax Department has responded directly based on current legal documents. Specifically, according to the provisions of point c, clause 1, Article 9 of Decree No. 320/2025/ND-CP:
Expenses with non-cash payment vouchers for the purchase and sale of goods, services and other payments each time have a value of 05 million VND or more". These vouchers must be made in accordance with the provisions of law on value-added tax.
From the above basis, the Tax Department determines: In case of paying salaries and wages to employees one time from 05 million VND or more without documents without using cash as prescribed, the deductible expenses are not recorded when determining corporate income taxable income.
Thus, if businesses still intentionally or unintentionally spend cash from 5 million VND or more each time on employees, this expenditure will "disappear" from the list of deductible expenses when determining corporate income tax (CIT). This means that the amount of CIT that businesses must pay will skyrocket unfortunately.
Immediately applicable to the 2025 tax period: No exceptions
Regarding the application time, Decree No. 320/2025/ND-CP takes effect from the date of signing and promulgation. In particular, the determination of the application time for the corporate income tax period starts from 2025.
Specifically, the regulations on non-cash payment vouchers at point c, clause 1, Article 9 are applied immediately from the time this Decree takes effect (December 15, 2025). The tax authority requests Mr. C. as well as businesses to compare the actual situation to properly implement legal regulations, avoiding errors that cause financial damage to the unit.
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