Official Letter No. 3896/CT-CS dated 11 June 2026 issued by the Tax Department provides guidance on the three-year Corporate Income Tax (CIT) exemption applicable to small and medium-sized foreign-invested enterprises (FDI enterprises) as follows:
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Where a foreign-invested enterprise is established and operates in accordance with the laws of Vietnam, has been granted its initial Enterprise Registration Certificate, satisfies the criteria for classification as a small or medium-sized enterprise under the Law on Support for Small and Medium-sized Enterprises and Decree No. 80/2021/ND-CP, and does not fall within the cases excluded from tax incentives as prescribed in Point (b), Clause 3, Article 7 of Decree No. 20/2026/ND-CP, it shall be entitled to a Corporate Income Tax (CIT) exemption for a period of three years from the date of issuance of its initial Enterprise Registration Certificate.
The CIT exemption shall not apply to income items specified in Clause 3, Article 18 of the Law on Corporate Income Tax No. 67/2025/QH15.
Accordingly, under Official Letter No. 3896/CT-CS of 2026, the Tax Department confirms that FDI enterprises meeting the criteria for classification as small and medium-sized enterprises are entitled to a three-year CIT exemption commencing from the date of issuance of their initial Enterprise Registration Certificate.
