According to a report from Quang Tri Trading Corporation (address: 01 Phan Boi Chau, Dong Ha City, Quang Tri Province), based on Decree No. 320/2025/NĐ-CP dated December 15, 2025, which outlines regulations and guidelines for certain provisions of the Corporate Income Tax Law, Section C, Clause 1, Article 9 stipulates: expenses with non-cash payment vouchers for purchases of goods, services, and other payments valued at 5 million VND or more per transaction.
The company inquires: in cases where wages are paid to employees in cash or in kind (without implementing non-cash payments as required), and the wage exceeds 5 million VND per person per payment, can this expense be deducted when determining taxable income for corporate income tax purposes?
In response, the tax authority refers to Clause 1, Article 9 of Decree No. 320/2025/NĐ-CP dated December 15, 2025 (effective from the 2025 corporate income tax period), which details provisions and measures for the implementation of the Corporate Income Tax Law, stating:
Article 9. Deductible Expenses When Determining Taxable Income
1. Except for non-deductible expenses as specified in Article 10 of this Decree, enterprises may deduct expenses when determining taxable income if they meet the conditions outlined in points a, b, and c below:
c) Expenses with non-cash payment vouchers for purchases of goods, services, and other payments valued at 5 million VND or more per transaction. Non-cash payment vouchers must comply with regulations outlined in legal documents concerning value-added tax.
Based on the above regulations, if an enterprise pays wages to employees in amounts of 5 million VND or more per payment without providing non-cash payment vouchers as required, such expenses cannot be deducted when determining taxable income for corporate income tax purposes.
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