Uni 29-12-2025 - Paying salaries from 5 million VND or more

The following is a Q&A session between the General Department of Taxation and businesses regarding the payment of salaries of 5 million VND or more:

Taxpayer: Quang Tri Trading Corporation

Address: 01 Phan Boi Chau Street, Dong Ha, Quang Tri

Based on Decree 320/2025 dated December 15, 2025, which regulates and guides some provisions of the Corporate Income Tax Law; Clause c, Point 1, Article 9 of the Decree states: Non-cash payment transactions with supporting documents are permitted for purchases of goods, services, and other payments with a value of VND 5 million or more per transaction. Non-cash payment documents must comply with the regulations of the law on value-added tax. Therefore, I would like to ask, if a business pays salaries to employees in cash or in kind (not through non-cash payment methods as stipulated) for each employee with a salary exceeding VND 5 million per person per payment, are these expenses deductible?

Answer:

Clause 1, Article 9 of Government Decree No. 320/2025/ND-CP dated December 15, 2025 (applicable from the corporate income tax assessment period of 2025) detailing some provisions and measures to organize and guide the implementation of the Corporate Income Tax Law stipulates:

"Article 9. Deductible expenses when determining taxable income

1. Except for non-deductible expenses as stipulated in Article 10 of this Decree, enterprises are allowed to deduct expenses when determining taxable income if they meet the conditions in points a, b, and c below:

…

c) Non-cash payment vouchers are required for purchases of goods, services, and other individual payments with a value of 5 million VND or more. Non-cash payment vouchers must comply with the regulations of the law on value-added tax.”

Based on the regulations mentioned above, in cases where a business pays its employees salaries of 5 million VND or more in installments without non-cash payment documentation as required, these payments cannot be included as deductible expenses when determining taxable corporate income.