Vietnamese capital gains tax - implementing decree issued
17 Dec 2025
On 15 December, the Government issued Decree 320/2025/ND-CP guiding the implementation of the new Corporate Income Tax law.
We now await the issuance of the guiding circular for this new decree.
Below are some notable points in this new decree:
1. Capital transfers by foreign corporate sellers are subject to 2% CIT on sale proceeds. This does not apply to internal group restructurings where the ultimate parent company of the Vietnamese subsidiary remains unchanged, and no gains arise.
2. Indirect capital transfers are taxable.
3. Securities transfers by foreign corporate sellers remain subject to 0.1% CIT on proceeds.
When do these new rules apply?
These new rules take effect from the date Decree 320 comes into force, which is 15 December.
