In brief
On 9 September 2025, the Government issued Resolution No. 05/2025/NQ-CP on the pilot implementation of the crypto asset market in Vietnam, establishing a regulatory framework for the offering, issuance, trading, and provision of crypto asset–related services.
To facilitate tax administration during the pilot phase, the Ministry of Finance subsequently issued:
- Circular No. 32/2026/TT-BTC dated 27 March 2026 (“Circular 32”), which provides regulations on Corporate Income Tax (CIT), Value-Added Tax (VAT), and Personal Income Tax (PIT) applicable to crypto asset transactions
- Circular No. 41/2026/TT-BTC dated 6 April 2026 (“Circular 41”), which sets out rules on tax declaration, withholding, payment, and tax finalization obligations in relation to the crypto asset market.
In depth
1. Scope of application
These tax regulations apply to:
- Crypto asset service providers
- Crypto asset issuers
- Vietnamese and foreign organizations and individuals engaging in crypto asset investment and activities in the crypto asset market in Vietnam
- Other relevant organizations and individuals involved in the offering and issuance of crypto assets.
2. Tax treatment
a. VAT
Crypto asset transfers and trading activities are not subject to VAT.
b. CIT
Vietnamese corporate sellers are subject to 20% CIT on income derived from crypto asset transfers. Taxable income is calculated as transfer proceeds minus the purchase cost of the transferred crypto assets and valid transfer-related expenses. Preferential CIT rates of 15% or 17% may apply if the sellers meet prescribed annual revenue thresholds.
Foreign corporate sellers conducting crypto asset transfer transactions through licensed crypto asset service providers are subject to 0.1% CIT on the gross transfer value per transaction.
c. PIT
Resident and non-resident individual sellers conducting crypto asset transfer transactions through licensed crypto asset service providers are subject to 0.1% PIT on the gross transfer price per transaction.
d. Timing for determination of revenue and income
The timing for determining revenue and income from crypto asset transfers follows the rules applicable to securities transfers under CIT and PIT regulations, as well as relevant crypto asset regulations.
3. Tax filings, withholding, and payment
- Crypto asset service providers and Vietnamese organizations engaged in the trading, transfer, or business of crypto assets are required to declare and pay CIT and VAT, perform CIT finalization, and use prescribed tax forms in accordance with prevailing tax regulations.
- Crypto asset service providers are responsible for withholding and remitting CIT and PIT arising from each crypto asset transfer transaction on behalf of foreign corporate sellers and individual sellers (both resident and non-resident). The withholding obligation arises upon confirmation of the successful completion of the transaction. Withheld CIT and PIT must be declared and remitted monthly.
- Crypto asset service providers are also responsible for issuing annual tax withholding certificates to foreign corporate sellers and individual sellers (both resident and non-resident).
Circular 32 and Circular 41 became effective on 27 March 2026 and 6 April 2026, respectively.
* * * * *
Thanh Vinh Nguyen, Partner, Thi Thanh Hoa Dao, Special Counsel, and Trung Kien Nguyen, Tax Practitioner, have co-authored this legal update.
© 2026 BMVN International LLC. All rights reserved. BMVN International LLC is in strategic alliance with Baker & McKenzie (Vietnam) Ltd., a member firm of Baker & McKenzie International, a global law firm with member law firms around the world. In accordance with the common terminology used in professional service organizations, reference to a “partner” means a person who is a partner, or equivalent, in such a law firm. Similarly, reference to an “office” means an office of any such law firm. This may qualify as “Attorney Advertising” requiring notice in some jurisdictions. Prior results do not guarantee a similar outcome.