Cashless Business: Mandatory Digital Payments Starting Dec 15 in Vietnam

On 15 December 2025, the Government promulgated Decree No. 320/2025/NĐ-CP detailing a number of articles and implementation measures of the Law on Corporate Income Tax. The Decree introduces several new provisions on non-cash payments made by enterprises that are deductible for corporate income tax purposes. Below, Viet An Law will update notable regulations related to cashless business: mandatory digital payments starting Dec 15 in Vietnam.

What is a cashless payment?

Pursuant to Clause 1 Article 3 of Decree No. 52/2024/NĐ-CP, cashless payment services include:

• Payment services via customer payment accounts: Provision of payment instruments; provision of cheque payment services, payment orders, credit transfers, collection orders, authorized collection, bank cards, money transfers, collection on behalf of customers, disbursement on behalf of customers and other payment services for customers via their payment accounts.
• Payment services not via customer payment accounts: The provision of payment services and the execution of payment transactions without going through the customer’s payment account.

“Cashless payment” may be understood as a method of payment that does not require direct transactions in cash, and is typically provided by financial institutions via electronic means such as credit cards, bank transfers, QR code scanning, etc.

Accordingly, documentary evidence of non-cash payment is shown through non-cash payment documents.

Cashless business: mandatory digital payments starting Dec 15 in Vietnam deductible for CIT

Pursuant to Clause 1 Article 9 of Decree No. 320/2025/NĐ-CP, cashless Business from 15 December 2025 that are deductible for CIT purposes include:

Purchases of goods, services and other payments, each time having a value of VND 5 million or more

Point c Clause 1 Article 9 of Decree No. 320/2025/NĐ-CP provides as follows:

“Article 9. Deductible expenses for determining taxable income

.1. Except for the non-deductible expenses stipulated in Article 10 of this Decree, an enterprise may deduct expenses when determining taxable income if the conditions specified at Points a, b and c below are fully satisfied:

[…] c) The expense is supported by non-cash payment evidence in the case of purchases of goods, services and other payments, each time having a value of VND 05 million or more. Non-cash payment evidence shall be implemented in accordance with the provisions of the legal documents on value-added tax.”

Accordingly, cashless business: mandatory digital payments starting Dec 15 in Vietnam, deductible for CIT applies to purchases of goods, services, and other payments, each time having a value of VND 05 million or more.

This provision is consistent with the conditions for input value-added tax credit. Specifically, purchases of goods and services with a value of VND 5 million or more are eligible for input value-added tax credit where there is non-cash payment evidence in accordance with Clause 1 Article 26 of Decree No. 181/2025/NĐ-CP.

Purchases of goods and services from the same seller multiple times in a day with an aggregate value of VND 05 million or more

Where an enterprise purchases goods or services from the same seller with the value of each purchase being less than VND 05 million, but the total value of purchases made multiple times in the same day is VND 05 million or more, such expenses are only deductible if there is non-cash payment evidence.

This provision is intended to prevent the practice of splitting transaction values in order to pay in cash, thereby ensuring transparency and consistency between the corporate income tax law and the value-added tax law.

Where the enterprise authorizes/assigns an employee to directly purchase goods or services on its behalf

Where an enterprise incurs expenses arising from cases in which the enterprise authorizes/assigns an employee to directly purchase goods or services on its behalf to serve the enterprise’s production and business activities, with an amount of VND 05 million or more, and such expenses are paid by the employee via non-cash payment services, they shall be treated as deductible expenses if all of the following conditions are satisfied:

• There are invoices and source documents in accordance with the provisions of the law on accounting, invoices and source documents;
• The enterprise has a financial regulation, internal regulation or decision providing for the authorization or permitting employees to make payments for purchases of goods and services serving the enterprise’s production and business activities;
• These expenses are subsequently reimbursed by the enterprise to the employee.

Accordingly, where the enterprise authorizes an employee to make payments on its behalf for purchases of goods or services of VND 05 million or more by non-cash payment methods, and all conditions on invoices, source documents, and internal authorization regulations are fully satisfied, such expenses shall still be treated as deductible when determining corporate income taxable income.

Case where payment has not yet been made at the time of expense recognition

• Where goods or services are purchased in a single transaction with a value of VND 05 million or more and, at the time of expense recognition, the enterprise has not yet made payment, the enterprise may still treat such amount as a deductible expense when determining taxable income.
• If, at the time of payment, the enterprise does not have non-cash payment evidence, the enterprise must declare and adjust to reduce expenses corresponding to the value of goods or services for which there is no non-cash payment evidence, in the tax period in which the cash payment arises.

This provision applies even where the tax authority or a competent authority has issued a decision on inspection or examination for the tax period in which such expense was incurred.

Allowances for employees on business trips, travel expenses and accommodation rental for employees on business trips where there are sufficient invoices and supporting documents

Pursuant to Point h Clause 1 Article 9 of Decree No. 320/2025/NĐ-CP, allowances for employees on business trips, travel expenses and accommodation rental for employees on business trips, where there are sufficient invoices and supporting documents, shall be treated as deductible expenses when determining taxable income.

Where an enterprise assigns an employee to go on a business trip (including domestic and overseas business trips), if expenses of VND 05 million or more arise and such expenses are paid by the individual via non-cash payment services, such expenses are deemed to satisfy the enterprise’s non-cash payment condition and shall be treated as deductible expenses if all of the following conditions are met:

• There are invoices and source documents in accordance with the provisions of the law on accounting and the law on invoices and source documents, issued by the supplier of goods or services;
• The enterprise has a decision or written document assigning the employee to go on a business trip;
• The enterprise’s financial regulation or internal regulation allows the employee to pay business-trip expenses and purchase tickets for means of transportation in his/her own name via non-cash payment services, and such expenses are subsequently reimbursed by the enterprise to the employee.

Note: Where an enterprise pays lump-sum amounts for travel expenses, accommodation expenses, and allowances to employees on business trips, and such payments are made in accordance with the enterprise’s financial regulations or internal regulations, the lump-sum travel, accommodation and allowance amounts shall be treated as deductible expenses.

Capital transfer value of VND 05 million or more under a transfer contract must have non-cash payment evidence

Pursuant to Point a.3 Clause 2 Article 13 of Decree No. 320/2025/NĐ-CP on determination of income from capital transfer, where an enterprise conducts a capital transfer to an organization or individual, the capital transfer value under any transfer contract with a value of VND 05 million or more must be supported by non-cash payment evidence.

Where a capital transfer is not supported by non-cash payment evidence, the tax authority is entitled to fix the transfer price.

The above is an update on the regulations concerning cashless business: mandatory digital payments starting Dec 15 in Vietnam. If you have any related questions or require advice on corporate income tax (CIT), please contact Viet An Law – Tax Agent for the best advice and support!