Official Letter No. 7563/NBI-QLDN3 dated 08 June 2026 issued by the Ninh Binh Provincial Tax Authority provides guidance on the deductibility of expenses relating to factory buildings available for lease during periods when no tenants have been secured

Where a company implemented an investment project before 2025, and the amended investment objectives include the activity of "leasing out surplus completed factory buildings", and the company elects to apply the revenue and expense provisions under Decree No. 320/2025/ND-CP from the beginning of the 2025 tax period, the following shall apply:

Where the Company has surplus factory buildings available for lease but has not yet secured any tenants, and such assets are under the Company's lawful ownership or right of use, the expenses relating to those assets during the vacancy period shall be deductible for Corporate Income Tax (CIT) purposes, provided that:

• The vacancy period commences from the time the Company is permitted to conduct the factory leasing business and the factory buildings are identified as surplus and officially re-designated for leasing purposes; and the expenses satisfy the conditions prescribed in Article 9 and do not fall within the non-deductible expense categories specified in Article 10 of Decree No. 320/2025/ND-CP.