The Tax Policy Management and Supervision Department (Ministry of Finance) has received the following documents: Document No. 261225.002/CV-ESA dated December 26, 2025, from ES Auditing LLC; an inquiry letter dated January 2, 2026, from Mr. Nguyen Van Cuong; Document No. 27/LNTH-KT dated January 14, 2026, from LN Tram Huong LLC; and Document No. 260116.03/VBDN-NTL dated January 16, 2026, from Nghiep Thanh Law LLC. These documents seek guidance on applying non-cash payment vouchers for salary and wage payments to employees, to be considered deductible expenses when determining corporate income tax (CIT) liability. In response, the Tax Policy Management and Supervision Department provides the following opinion:
Article 9(1)(c) of the Law on Corporate Income Tax No. 67/2025/QH15 stipulates:
“Article 9. Deductible and Non-Deductible Expenses for Taxable Income Determination
Except for expenses specified in Clause 2 of this Article, enterprises may deduct expenses when determining taxable income if the following conditions are met:
c) Expenses supported by non-cash payment vouchers as prescribed by law, except for specific cases as regulated by the Government.”
Article 9(1) of Decree No. 320/2025/NĐ-CP dated December 15, 2025, issued by the Government, provides detailed guidelines for implementing certain provisions of the Law on Corporate Income Tax:
“Article 9. Deductible Expenses for Taxable Income Determination
Except for non-deductible expenses outlined in Article 10 of this Decree, enterprises may deduct expenses when determining taxable income if the following conditions are met:
a) The expense is directly related to the enterprise’s production and business activities.
b) The expense is supported by valid invoices and documents as prescribed by law.
c) For purchases of goods, services, and other payments of VND 5 million or more per transaction, non-cash payment vouchers must be provided, in accordance with regulations on value-added tax.”
Regarding non-cash payment vouchers, Article 26 of Decree No. 181/2025/NĐ-CP dated July 1, 2025, which details the implementation of certain provisions of the Law on Value-Added Tax, defines:
“Non-cash payment vouchers are documents proving non-cash payments as stipulated in Decree No. 52/2024/NĐ-CP dated May 15, 2024, issued by the Government, excluding cases where the buyer deposits cash into the seller’s account.”
Article 10(8)(a) of Decree No. 320/2025/NĐ-CP outlines non-deductible expenses, including:
“8. Payments to employees in the following cases:
a) Salary, wage, and other payments to employees that have been recorded as production and business expenses but were not actually paid or lack valid payment vouchers as prescribed by law.”
Article 24(1)(b) of Decree No. 320/2025/NĐ-CP states:
“Article 24. Effective Date
1. This Decree takes effect from the date of issuance and applies to the corporate income tax period starting from 2025. Specific application timelines are as follows:
b) Provisions on non-cash payment vouchers in Article 9(1)(c) and capital transfer regulations in Article 12(3)(i) of this Decree apply from the effective date of this Decree.”
Based on the above regulations, the Ministry of Finance clarifies: If an enterprise’s salary and wage payments to employees meet the conditions outlined in Article 9(1) of Decree No. 320/2025/NĐ-CP and do not fall under the non-deductible expenses listed in Article 10(8) of the same Decree, such payments are considered deductible expenses for CIT purposes.
For salary and wage payments of VND 5 million or more per transaction, effective from the date Decree No. 320/2025/NĐ-CP takes effect (December 15, 2025), enterprises must provide non-cash payment vouchers as specified in Article 26 of Decree No. 181/2025/NĐ-CP to qualify for deduction.
This document serves as official guidance for enterprises and individuals to comply with the regulations.
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