The government of Vietnam issued Decree 20/2026/ND-CP to clarify the relevant tax exemption policy as follows:

1. The corporate income tax for small and medium-sized enterprises shall be exempted for 3 years from the date of issuance of the first enterprise registration certificate.
2. The tax exemption period is calculated continuously, starting from the first year the enterprise is granted the initial enterprise registration certificate, regardless of whether the enterprise generates revenue or profit in that year or not.
3. For cases where the enterprise registration certificate is issued before Resolution No.198/2025/QH15 takes effect, but there is still a time to enjoy tax exemption, enterprises are still entitled to continue to enjoy corporate income tax exemption for the remaining time.

However, the following circumstances are not eligible for the above-mentioned corporate income tax exemption benefits:

1. Newly established enterprises arising from mergers, consolidations, divisions, separations, ownership conversions or business type conversions.
2. A newly established enterprise where the legal representative, member of the partnership or the person with the highest capital contribution has participated in business activities with the above-mentioned roles in another operating enterprise, or the enterprise has been dissolved but not enough 12 months, calculated from the time of dissolution to the time of establishment of the new enterprise.
3. Income items that are not eligible for tax incentives, as stipulated in Clause 3, Article 18 of the Law on Corporate Income Tax.

Small and medium-sized enterprises refer to enterprises with an average annual participation of no more than 200 employees in social insurance and meeting one of the following two criteria:

1. The total assets not exceeding VND100 billion;
2. The total revenue of the previous year not exceeding VND300 billion.