This clarification was recently issued by the Department for Tax Policy Oversight under the Ministry of Finance, in response to requests from businesses and individuals seeking guidance on non-cash payment requirements when paying employee wages - especially in the context of determining deductible expenses for corporate income tax (CIT).

According to Point c, Clause 1, Article 9 of the Law on Corporate Income Tax No. 67/2025/QH15, deductible expenses must meet certain conditions, including being supported by valid invoices and proof of non-cash payment, except in special cases specified by the Government.

Clause 1, Article 9 of Decree No. 320/2025, which guides implementation of the CIT law, reiterates this:

Except for non-deductible expenses listed in Article 10 of the Decree, business expenses may be deducted from taxable income if they meet the following criteria:

The expense is actually incurred in relation to business operations.

It is supported by appropriate legal invoices or documentation.

It is supported by non-cash payment proof for transactions of 5 million VND or more, including purchases of goods, services, or other payments. The documentation must comply with VAT regulations on non-cash payments.
Under Article 26 of Decree No. 181/2025 (implementing provisions of the VAT Law), non-cash payment documents are defined as evidence of payments made via cashless methods under Decree No. 52/2024 on non-cash transactions. It excludes situations where the buyer deposits cash directly into the seller’s account.

Point a, Clause 8, Article 10 of Decree No. 320/2025 also outlines cases where wage expenses are not deductible. These include situations where salary and wage amounts have been recorded as business expenses but are either unpaid or lack proper payment documentation.

Per Clause 1, Article 24 of Decree 320/2025, the decree took effect upon signing and applies from the 2025 tax year onward. Specifically, the requirement for non-cash documentation in wage payments (Point c, Clause 1, Article 9) came into force on December 15, 2025.

Accordingly, if a business pays wages or salaries of 5 million VND or more per instance to an employee, it must provide non-cash proof of payment from December 15 onward in order for these payments to be treated as deductible expenses.

The Department for Tax Policy Oversight emphasized that wage expenses that meet the criteria set out in Article 9 and are not covered by the exceptions in Article 10 of Decree 320 will continue to be considered valid deductible expenses - so long as non-cash proof is provided for transactions from 5 million VND upward.

Proof of non-cash payment must be in line with Article 26 of Decree 181/2025 on the implementation of the VAT Law.

Nguyen Le