New rules issued on the Law on Corporate Income Tax 2025
19 Dec 2025
The Government has just issued a new decree guiding the 2025 Law on Corporate Income Tax. The new decree takes effect from its signing date (i.e. 15 December 2025) and apply for the tax year 2025 onwards.
The Decree provides more detailed rules on CIT-exempt profits, revenue recognition, profits from overseas investment, and deductible/non-deductible expenses.
CIT incentives are significantly changed, including contents for “special” incentives, definition of incentivised locations, thresholds for expansion projects.
The Decree also introduces a number of new concepts and preferential treatments, e.g. for digital permanent establishment, “green” activities and R&D super-deduction, and interfaces with the global minimum tax rules.
Transitional provisions allow taxpayers some flexibility in selecting the applicable regime from 2025, and clarify the treatment of existing incentives and carried forward tax losses.
