[Vietnam Biz – Part 13] CIT Law 2025 Amendments on preferential tax policies for the manufacturing sector: What are the changes and who is eligible? (Part 6)

Reviewing Investment Strategies and Practical Considerations After the 2025 CIT Law Amendments

With the implementation of the 2025 CIT Law, corporate income tax (CIT) incentives for the manufacturing sector have been significantly revised. Previously, the system was applied based on a simple criterion—“two years of tax exemption and four years of 50% tax reduction” merely for being located in an industrial park. Going forward, however, a multifaceted evaluation will be required, including factors such as technology level, industry classification, investment scale, and regional requirements.

It is now more important than ever to make comprehensive judgments that consider not only tax incentives but also related preferential schemes such as land rental reductions and customs duty exemptions. Below is a step-by-step explanation of the key practical points to keep in mind when reviewing post-amendment investment strategies.

6.1. Confirm Related Incentives Beyond Preferential Tax Treatment

Focusing solely on tax incentives risks overlooking important cost factors such as land rental exemptions/reductions and import duty exemptions. Following the 2025 amendments, preferential measures affecting investment costs beyond corporate income tax have become more diversified, particularly in specific regions and priority industries where eligibility conditions have been further segmented.

Therefore, when considering tax incentives, it is essential to investigate these related schemes as well and assess the overall cost benefits comprehensively. In some cases, non-tax incentives may have an even greater impact on business planning.

• ・Confirm the availability of land rental exemption/reduction schemes

• ・Understand eligible items and conditions for import duty exemptions

• ・Pay attention to differences in incentives by region and industry

• ・Evaluate the impact of non-tax cost incentives on business plans

• ・Consider whether multiple incentive schemes can be combined

6.2. Emphasize Requirements Beyond Location Conditions

The previous approach—where simply entering an industrial park automatically qualified a project for incentives—will no longer apply. Greater emphasis is now placed on new evaluation criteria such as technological level, industry classification, and investment scale. For example, there has been an increase in cases where high-tech, green industries, and advanced technology sectors qualify for preferential treatment.

Furthermore, eligibility may vary depending on regional socio-economic conditions and project scale. Therefore, beyond selecting a location, companies must rigorously verify whether their project meets multiple criteria.

• ・Confirm compliance with required technological levels and industry classifications

• ・Investigate investment scale and job creation requirements

• ・Check alignment with national industrial policies

• ・Compare socio-economic conditions across regions

• ・Verify whether the company’s plan satisfies the composite criteria

6.3. Determine Whether Continued Application or New Application Applies

The new rules apply to projects that obtain investment approval on or after October 1, 2025. As a result, the system diverges between existing and new projects. In principle, projects already receiving incentives may continue under the old regime; however, depending on specific conditions, transition to the new system may be required. Therefore, accurate confirmation of approval dates and contractual details is crucial.

For new projects, compliance with new standards—such as technological classification and regional requirements—is mandatory. Misjudging the applicable regime or eligibility for continued application may increase the risk of unexpected cost increases or loss of incentives.

6.4. Reduce Risk Through Collaboration with Experts

Following the 2025 amendments, the determination and application of incentive schemes have become increasingly complex. For each project, detailed judgments are required regarding eligibility for continued application of the old rules or transition to the new regime.

In this environment, early consultation with tax and legal experts or consultants is directly linked to risk reduction. Based on up-to-date information, companies can select the most appropriate incentive application pattern. In particular, professional confirmation is indispensable regarding approval dates, contract renewals, and the possibility of combining multiple incentives.

• ・Consult tax and legal experts at an early stage

• ・Regularly obtain the latest decrees and circulars

• ・Confirm treatment of approval dates and contract renewals

• ・Seek professional judgment on the combinability of incentives

• ・Utilize external expertise to ensure appropriate investment decisions

6.5. Continuously Monitor the Latest Developments in System Changes

Economic policies and tax administration are expected to continue evolving. It is therefore essential to stay informed about the latest developments. Detailed implementation guidelines, decrees, and circulars related to the 2025 CIT Law are scheduled to be issued in stages. Regular review of such information and reflection in investment planning and business operations will help minimize the risk of unforeseen regulatory changes.

If internal information-gathering is limited, leveraging the latest reports and seminars from experts or industry associations can be effective. Going forward, companies are expected to actively incorporate external information and develop flexible and responsive capabilities.

★ Key Summary Points of CIT Law 2025 Preferential Tax Policies for the Manufacturing Sector

The 2025 amendments to the CIT Law have significantly changed the eligibility conditions for preferential tax treatment available to manufacturing companies. Policy focus has shifted from location-based criteria—such as simply being located in an industrial park—to requirements aimed at higher economic value, including industry classification, technological standards, and investment scale.

Going forward, strategic and multi-layered investment decisions will be essential. These include prioritization of key industries and high-tech sectors, continued incentives for regions with special socio-economic conditions, and phased preferential tax rates for SMEs. As different rules apply to existing and new projects, careful attention must be paid to approval dates and selection of the applicable regime.

In addition, accurate documentation management—such as preparation of investment plans and supporting materials—and proper diagnosis of eligibility requirements are critical from a practical standpoint. By closely monitoring forthcoming decrees and circulars and formulating flexible and detailed investment strategies, companies can effectively leverage the opportunities presented by the 2025 CIT Law amendments.