Tariff and Vietnam’s Corporate Income Tax Law No. 67/2025/QH15: What Businesses Need to Know

Vietnam is entering a new phase of fiscal modernization. With the Corporate Income Tax (CIT) Law No. 67/2025/QH15 taking effect on October 1, 2025, the Vietnamese government aims to harmonize its tax and tariff systems to maintain economic competitiveness while aligning with global tax reforms such as the OECD’s Global Minimum Tax (GMT).

This new law will apply to the 2025 tax year and replaces the previous Corporate Income Tax Law (2008) and its amendments. Together with tariff adjustments and customs modernization, the reform represents a strategic shift in Vietnam’s financial policy — designed to strengthen investment appeal, promote sustainability, and ensure fair taxation across industries.

Vietnam’s Corporate Tax Law 67/2025 — Key updates for business and compliance.

Understanding the Relationship Between Tariffs and Corporate Tax

While tariffs and corporate income tax operate under different fiscal regimes, both play crucial roles in Vietnam’s overall tax policy. Tariffs — import and export duties imposed at customs — influence the cost structure and profit margins of enterprises. Corporate income tax, on the other hand, directly affects net profitability and reinvestment capacity.

For multinational corporations and import-dependent manufacturers, these two policy tools are closely linked. When tariffs are reduced under free trade agreements (FTAs) such as the EVFTA or CPTPP, businesses enjoy lower input costs but are expected to report higher taxable profits under CIT. Conversely, higher tariffs may reduce gross margins but can also serve as protection for domestic producers, balancing local tax revenues.

This dual mechanism highlights why Vietnam’s 2025 tax reform is not only a corporate taxation update, but also a comprehensive tariff-policy adjustment aligning with long-term national competitiveness goals.

Key Highlights of the Corporate Income Tax Law No. 67/2025/QH15

The new CIT Law 67/2025/QH15, approved by the National Assembly on June 14, 2025, introduces several critical changes impacting all business types — from small domestic enterprises to multinational groups.

1. Updated Tax Rates Based on Business Scale

The standard corporate tax rate remains 20%, but new progressive rates now apply based on annual revenue:

• 15% for small enterprises with annual revenue ≤ VND 3 billion

• 17% for medium-sized enterprises with revenue between VND 3 billion – 50 billion

• 20% for large enterprises above that threshold

• Higher rates still apply for natural resource exploration and oil extraction.

This structure reflects Vietnam’s strategy to support SMEs while maintaining stable revenue collection from larger corporations.

2. Expanded Tax Exemptions and Incentives

Vietnam’s 2025 law significantly broadens tax-exempt income categories, especially in areas aligned with global sustainability trends:

• Income from carbon credit transfers or certified emission reductions (CERs).

• Income from green bonds or environmentally sustainable investment projects.

• Tax incentives for high-tech manufacturing, renewable energy, and R&D centers.

These incentives align Vietnam’s tax policy with its net-zero commitments and the nation’s ESG investment roadmap for 2050.

3. Global Minimum Tax (GMT) Compliance

The new law incorporates Vietnam’s obligations under the OECD’s BEPS Pillar 2 initiative. Multinational enterprises with consolidated revenues over EUR 750 million are now subject to a top-up tax if their effective tax rate in Vietnam falls below 15%.

This ensures tax fairness and prevents base erosion while maintaining Vietnam’s attractiveness through targeted non-tax incentives, such as land rent reductions or administrative simplifications.

4. Tax Period and Declaration Rules

Businesses can now choose between a calendar year or a financial year as their tax period. However, they must notify tax authorities before their first filing. This flexibility helps multinational groups align Vietnam’s reporting with their global accounting cycles — improving compliance efficiency.

5. Carry-Forward Losses and Science & Technology Fund

Enterprises may carry forward tax losses for up to five consecutive years, ensuring smoother recovery after volatile business cycles. Additionally, firms can allocate up to 20% of taxable income annually to a Science & Technology Fund, provided that it is used for qualified R&D activities within five years. Misuse or failure to utilize the fund will result in retrospective taxation.

Tariff Adjustments Under the 2025 Fiscal Framework

Parallel to the corporate income tax reform, Vietnam is expected to revise its tariff schedule to comply with ASEAN and WTO commitments. The 2025 tariff framework aims to:

• Simplify customs classifications under the HS system.

• Reduce tariffs on raw materials and high-tech components to encourage local manufacturing.

• Maintain protective duties on sensitive sectors like agriculture and beverages.

• Expand preferential tariff rates under FTAs such as the RCEP and EVFTA.

For export-oriented businesses, reduced import tariffs on production inputs mean lower production costs, while domestic manufacturers may face new competition. Tariff alignment with regional norms is thus both a challenge and an opportunity for businesses operating in Vietnam’s supply chain ecosystem.

Winners and Losers Under the 2025 Tax Reform

The combined effect of tariff realignment and new CIT provisions will not be uniform across industries:

• Beneficiaries: Small and medium-sized enterprises, high-tech firms, renewable energy projects, and R&D-focused investors. These groups gain from lower CIT rates and extended incentives.

• Neutral or Mixed Impact: Export-driven manufacturers benefit from reduced tariffs but face tighter compliance under GMT.

• Adversely Affected: Companies in real estate, digital entertainment, or capital transfer transactions — sectors excluded from new tax incentives — may face higher effective tax burdens.

The key takeaway for investors is to model their post-2025 tax exposure early, factoring in both tariff revisions and adjusted profit taxation.

Practical Guide and Checklist for Businesses

To prepare for the October 2025 implementation, businesses should take a proactive compliance approach. The following checklist summarizes critical actions:

1. Review Current Tax Obligations — Reassess your enterprise’s tax structure and current incentive status under pre-2025 law.

2. Evaluate Revenue Thresholds — Determine if you qualify for the 15% or 17% CIT bracket.

3. Recalculate Supply Chain Costs — Update cost models based on new tariff rates and input duties.

4. Identify Eligible Incentives — Explore tax relief for green projects, R&D activities, or technology investments.

5. Ensure GMT Readiness — For multinational groups, verify global tax rate computations to comply with the new top-up mechanism.

6. Consult Local Advisors — Engage tax experts familiar with Vietnam’s customs, tariff codes, and FDI compliance rules.

This structured approach enables businesses to minimize fiscal risks while leveraging new opportunities.

Policy Outlook and Economic Implications

Vietnam’s 2025 tax reform represents more than a technical adjustment — it signals a strategic economic transformation. By lowering rates for smaller enterprises, aligning tariffs with trade agreements, and adopting the global minimum tax, Vietnam is strengthening both transparency and investor confidence.

Experts from the World Bank and AmCham Vietnam forecast that these reforms could enhance Vietnam’s tax-to-GDP ratio while preserving its status as a preferred manufacturing hub in Asia. Over the next decade, stable tax policy and simplified tariffs are expected to drive increased foreign direct investment (FDI), particularly in high-value, green, and digital industries.

Frequently Asked Questions (FAQ)

1. When does the new Corporate Income Tax Law take effect? → From October 1, 2025, applying to the 2025 fiscal year onward.

2. What is the standard corporate tax rate? → 20%, with preferential rates of 15% and 17% for smaller firms.

3. Will the law affect foreign investors? → Yes. Multinationals under the OECD framework must comply with Vietnam’s Global Minimum Tax provisions.

4. Are tariff reductions part of this reform? → Yes. Vietnam is simultaneously updating its tariff schedule to enhance FTA integration and lower input costs for manufacturers.

Conclusion

The Corporate Income Tax Law No. 67/2025/QH15 and accompanying tariff adjustments mark a pivotal moment in Vietnam’s fiscal evolution. By simplifying tax tiers, incentivizing innovation, and embracing global tax standards, the law positions Vietnam for sustainable, transparent, and inclusive economic growth.

For businesses, preparation is essential. Companies should review their tax exposure, model cost scenarios, and align compliance frameworks before the law takes effect on October 1, 2025. In a landscape where tariffs, trade, and taxation converge, proactive adaptation will distinguish the most resilient and competitive enterprises in Vietnam’s next economic chapter.

Your Business Deserves Real Legal Minds

Vinex offers expert legal and business services for investors entering Vietnam:

• Company Formation: Secure ERC/IRC in 1-3 months.

• Legal & Tax Advisory: Ensure compliance with Vietnam export duties to U.S. and local laws.

• Banking & Logistics: Optimize accounts and supply chains. Contact Vinex at +84 98 1111 811 or contact@vinex.com.vn to launch your venture.