Decree 320/2025/ND-CP Guiding the Implementation of the Corporate Income Tax Law

In addition to detailing the aforementioned articles of the Law, the Decree also guides the measures for organizing the implementation of the Corporate Income Tax Law, focusing on core contents such as: determining taxable income; basis for tax calculation; tax rates; tax calculation methods; principles and subjects of application of corporate income tax incentives; preferential tax rates; tax exemptions and reductions; conditions for enjoying tax incentives;  appropriation to the science and technology development fund of the enterprise; as well as regulations on effectiveness.

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Regarding the scope of application, Decree No.320/2025/ND-CP applies to organizations and individuals related to the scope of the Decree.
Taxpayers of corporate income tax under the Decree include enterprises established and operating under Vietnamese law such as the Enterprise Law, Investment Law, Insurance Business Law, Securities Law,  Petroleum Law, Commercial Law, and other relevant legal documents. Enterprises established under Vietnamese law are obligated to pay tax on taxable income arising both within and outside Vietnam.
For foreign enterprises, the Decree clearly defines tax obligations according to each case, including: foreign enterprises with or without a permanent establishment in Vietnam; foreign enterprises with a permanent establishment but generating income unrelated to the activities of the permanent establishment; and foreign enterprises providing goods and services in Vietnam through e-commerce and digital platforms. These businesses are all required to pay taxes on taxable income generated in Vietnam according to regulations.
In addition, the Decree stipulates the responsibility for tax payment on behalf of organizations established and operating under Vietnamese law in cases of purchasing services, business cooperation, e-commerce business, business on digital platforms, or receiving capital transfers from foreign businesses. Securities investment fund management companies are also identified as tax payers on behalf of foreign businesses in certain cases as stipulated.
Decree No.320/2025/ND-CP also clarifies the concept of a permanent establishment of a foreign business, including branches, executive offices, factories, construction works, service providers, agents, representatives in Vietnam, and e-commerce platforms and digital platforms through which foreign businesses provide goods and services in Vietnam.

Source: https://luatvietnam.vn/tin-van-ban-moi/da-co-nghi-dinh-320-2025-nd-cp-huong-dan-thi-hanh-luat-thue-thu-nhap-doanh-nghiep-186-105947-article.html