CORPORATE INCOME TAX (CIT) EXEMPTION FOR SMALL AND MEDIUM-SIZED ENTERPRISES
UNDER DECREE 20/2026/ND-CP
1. Three-Year CIT Exemption for Newly Established Enterprises
Pursuant to Clause 3, Article 7 of the Decree guiding the CIT exemption for small and medium-sized enterprises (SMEs) registering their business for the first time:
Enterprises are exempt from Corporate Income Tax for three (3) years, counted from the date of issuance of the Enterprise Registration Certificate for the first time.
- The exemption period is calculated continuously, starting from the year in which the Enterprise Registration Certificate is first issued.
- The exemption applies regardless of whether the enterprise generates taxable profits, provided that it qualifies for the incentive.
Case where the enterprise was established before 17 May 2025
Where the Enterprise Registration Certificate was issued before 17 May 2025 and the enterprise still has remaining incentive time as of that date, the enterprise shall continue to enjoy the CIT exemption for the remaining period in accordance with this provision.
Example (Assumption)
- The Enterprise Registration Certificate was first issued in June 2024.
- The enterprise qualifies for a three-year CIT exemption under the regulation.
As of 17 May 2025, the enterprise is in the second year of its exemption period.
Accordingly, the enterprise shall continue to enjoy the CIT exemption for the remaining period (2025–2026) in accordance with the regulation.
Important Notes – Cases Not Eligible for the Incentive
(i) Enterprises newly established as a result of:
- Merger, consolidation, division or separation;
- Change of ownership;
- Conversion of enterprise type.
(ii) Newly established enterprises where:
- The legal representative (except where such person is not a capital-contributing member).
- or a general partner.
- or the person holding the highest capital contribution ratio.
Has previously held the same position in another enterprise.
Has held or is currently holding one of the above positions in another enterprise that is:
Still operating; or
Has been dissolved for less than 12 months (counted from the date of dissolution of the former enterprise to the date of establishment of the new enterprise).
(iii)
2. Criteria for Determining Small and Medium-Sized Enterprises
Pursuant to Article 5 of Decree 80/2021/ND-CP, detailed criteria for determining small and medium-sized enterprises eligible for the three-year CIT exemption include:
Enterprise Category | Sector | Average Annual Employees Participating in Social Insurance | Maximum Annual Revenue | OR Maximum Total Capital |
| Micro Enterprise | Agriculture, Forestry, Fishery; Industry and Construction | ≤ 10 employees | ≤ VND 3 billion | ≤ VND 3 billion |
| Trade and Services | ≤ 10 employees | ≤ VND 10 billion | ≤ VND 3 billion | |
| Small Enterprise | Agriculture, Forestry, Fishery; Industry and Construction | ≤ 100 employees | ≤ VND 50 billion | ≤ VND 20 billion |
| Trade and Services | ≤ 50 employees | ≤ VND 100 billion | ≤ VND 50 billion | |
| Medium Enterprise | Agriculture, Forestry, Fishery; Industry and Construction | ≤ 200 employees | ≤ VND 200 billion | ≤ VND 100 billion |
| Trade and Services | ≤ 100 employees | ≤ VND 300 billion | ≤ VND 100 billion |