Foreign companies do not all follow the same Vietnam tax route. A company established in Vietnam and an overseas supplier earning Vietnam-source income can have different tax and filing responsibilities; digital-platform supplies also need separate review. Start with the legal entity, contract, payment flow and tax period—not a headline tax rate.
First determine how the business earns income in Vietnam
The key first distinction is whether the business operates through a locally established enterprise or receives income from Vietnam as an overseas supplier. The corporate income tax, VAT and tax-administration rules relevant to one arrangement do not automatically describe the other. A Vietnamese payer may also have withholding, declaration or remittance duties for payments to a foreign contractor.
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| Situation | What to investigate first |
|---|---|
| Locally established enterprise | Which current corporate income tax, VAT, tax-administration and e-invoice rules apply to the entity and its transactions. |
| Overseas contractor paid under a Vietnam-related contract | Whether the income and contract bring foreign contractor tax procedures into play, and which party must withhold, declare and pay. |
| Foreign business supplying goods or services through an e-commerce or digital platform | How the current corporate income tax framework applies and which registration and payment mechanism, if any, governs the specific supply. |
These are starting points, not conclusions about tax residence, taxable presence or liability. Contract terms, what is supplied, where the income arises, who pays, and the relevant tax period can change the answer.
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Which current laws and dates matter?
Vietnam’s rules changed across 2025 and 2026, so use the law applicable to the transaction’s tax period rather than assuming an older guide is current.
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- Tax administration: The government lists Law No. 108/2025/QH15 on Tax Administration as effective 1 July 2026. Government reporting identifies specified provisions, including provisions concerning tax administration and e-invoices, as effective from 1 January 2026. The start date for the law as a whole and the earlier start date for specified provisions are distinct.
- Corporate income tax: Government reporting says the 2025 Corporate Income Tax Law took effect on 1 October 2025. A consolidated text was issued on 20 May 2026.
- VAT: Law No. 149/2025/QH15 amended the VAT law effective 1 January 2026. The government published a consolidated VAT text on 6 February 2026.
For a filing or transaction, check the operative consolidated text and any applicable implementing rules for the relevant period. A law’s effective date alone does not determine the rate, exemption or filing treatment for every supply.
What corporate income tax and VAT should a foreign company check?
Corporate income tax
For a locally established business, identify the rules in the 2025 corporate income tax law and the consolidated text issued in May 2026, then verify how they apply to the entity’s income and tax period. Do not assume a rate from an older article applies to every taxpayer or income category: the available official information here does not establish a single rate suitable for all cases.
Foreign businesses supplying goods or services in Vietnam through e-commerce or digital platforms are included in the tax provisions described in government reporting on the new law. That is a reason to check the operative consolidated text and the applicable registration and payment mechanism; it is not, by itself, a complete determination of whether a particular business has a tax obligation or how it must comply.
Value-added tax
Use the VAT law as amended from 1 January 2026 and its February 2026 consolidated text to classify the actual goods or services and relevant transaction date. There is no safe universal VAT rate to apply without that classification and a check of the rule in force for the period.
When does foreign contractor tax apply, and who files?
For an overseas supplier, assess the contract and payment flow before treating a payment as subject to foreign contractor tax. Then establish which responsibilities fall on the foreign contractor and which fall on the Vietnamese payer under the applicable rules. Do not treat the tax label as proof that the foreign supplier alone must file or remit.
Ministry of Finance procedure pages describe declarations when a tax liability arises, a monthly option in specified circumstances, and finalization when the contract ends. The procedure summary gives these filing patterns:
| Pattern described by the procedure summary | Stated deadline | Qualification |
|---|---|---|
| Declaration tied to a tax-liability event | No later than the 10th day after the liability arises | Deadline stated on the Ministry of Finance procedure page; verify that the pattern applies to the contract and current rules. |
| Monthly declarations where the option is available | No later than the 20th day of the following month | Available only in specified circumstances; confirm eligibility and applicable calendar treatment. |
| Contract-end finalization | At contract end under the applicable procedure | The procedure information says the Vietnamese payer’s tax authority receives contractor tax finalization materials. Confirm who must prepare and submit them for the particular arrangement. |
These are procedure-page deadlines, not a complete calendar for every contractor or tax period. Confirm the current filing rules, the responsible party and any calendar adjustment before relying on a date.
How much weight should you give Circular 103/2014?
The Ministry of Finance legal database hosts Circular 103/2014, which describes a declaration method conditioned on factors including a Vietnam permanent establishment or residence, contract activity lasting at least 183 days, Vietnamese accounting and tax registration. It also describes payer-side tax substitution where a foreign contractor does not meet one of its listed conditions.
Because Circular 103 dates from 2014 and newer tax statutes have since taken effect, those criteria should be treated as a description of the circular—not assumed to be the complete current test. Check current implementing rules before using them to choose a filing method or assign payment responsibility.
A practical compliance sequence
- Map the arrangement. Record the contracting parties, entity form, goods or services supplied, where the income arises, payment route and whether a digital platform is involved.
- Set the relevant period. Identify when the income or transaction arose and match it to the applicable corporate income tax, VAT and tax-administration rules, including the 2025–2026 changes.
- Classify each tax separately. Review corporate income tax treatment, VAT treatment and any foreign contractor procedure independently; one classification does not settle the others.
- Assign each compliance task. Document who must withhold, declare, pay, keep records and complete any contract-end finalization. Confirm the allocation under the applicable current rules rather than relying only on contract wording.
- Confirm forms, deadlines and records. Check the current official procedure for the entity and filing pattern, including whether a monthly option is available and how the deadline is counted. Retain the contract, invoices, payment evidence and filing records needed to support the treatment.
For a cross-border contract, platform supply or uncertain payer/contractor allocation, obtain advice from a Vietnam tax professional based on the actual documents and payment flow. This overview is not a transaction-specific tax opinion.
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