Date of issuance: 02 April 2025

Effective year: 2025

In early 2025, Vietnam continues to navigate a complex economic environment shaped by persistent global uncertainties, subdued domestic consumption, and ongoing cost pressures faced by businesses across multiple sectors. While macroeconomic indicators remain broadly stable, many enterprises, particularly small and medium-sized businesses and those operating in labour-intensive or capital-heavy industries, continue to face liquidity constraints.

In this context, the Government issued Decree No. 82/2025/NĐ-CP (“Decree 82”) as a targeted fiscal support measure aimed at easing short-term financial pressure on taxpayers while maintaining overall tax policy consistency. Rather than altering tax rates or introducing new incentives, Decree 82 focuses on extending payment deadlines for several key taxes and land rent obligations arising in 2025.

The decree represents one of the most comprehensive tax payment extension frameworks in recent years, covering value-added tax (VAT), corporate income tax (CIT), personal income tax (PIT) for business households and individuals, and land rent. Its scope spans a wide range of industries and taxpayer types, reflecting the Government’s intention to provide broad-based yet temporary relief to support business continuity and economic recovery.

Policy Rationale and Objectives

The issuance of Decree 82 aligns with the Government’s broader economic management strategy in 2025, which prioritises business stabilisation, employment protection, and the restoration of production and service activities. Instead of permanent tax reductions, which could impact fiscal balance, the Government has opted for time-based relief, allowing taxpayers to defer payments while retaining full tax liabilities.

This approach serves several objectives:

• Alleviating short-term cash flow pressures for enterprises and individuals;
• Supporting sectors facing slower demand recovery or higher operating costs;
• Preserving state budget revenue in the medium to long term;
• Maintaining consistency with Vietnam’s tax administration and compliance framework.

Decree 82 thus functions as a liquidity support mechanism rather than a structural tax reform, reinforcing the principle that deferred taxes remain payable once extension periods expire.

Scope of Eligible Taxpayers

Unlike earlier extension decrees that were narrowly targeted or sector-specific, Decree 82 adopts a broad eligibility framework. Article 3 of the decree outlines multiple categories of taxpayers entitled to apply for extensions, significantly expanding its practical reach.

Enterprises and organisations by sector

Eligible entities include enterprises and organisations operating in a wide range of industries, notably:

• Manufacturing and production, such as agriculture, forestry, aquaculture, food processing, chemicals, mechanics, electronics, and automobile manufacturing;
• Service sectors, including transportation, logistics, accommodation, education, healthcare, real estate, tourism, and related services;
• Construction, publishing, broadcasting, creative industries, and other cultural sectors;
• Information and communication technology (ICT), telecommunications, and digital services.

This inclusive approach reflects the recognition that economic challenges in 2025 are not confined to a single industry but are affecting both traditional and emerging sectors.

Supporting industries and priority manufacturing

Enterprises engaged in:

• The production of priority supporting industry products; and
• The manufacture of key mechanical products
• are also eligible, reinforcing the Government’s long-term industrial development and localisation strategies.

Small and micro enterprises

Small and micro enterprises, as defined under:

• The Law on Support for Small and Medium-sized Enterprises (2017); and
• Decree No. 80/2021/NĐ-CP

automatically fall within the scope of Decree 82, recognising their heightened vulnerability to cash flow disruptions and limited access to financing.

Business households and individuals

In addition to corporate taxpayers, Decree 82 extends relief to business households and individuals, particularly in relation to VAT and PIT obligations arising in 2025. This marks an important expansion compared to earlier measures that focused primarily on corporate entities.

Extension of Value-Added Tax (VAT) Payments

Applicable taxpayers and periods

VAT payment extensions apply to eligible enterprises and organisations for:

• Monthly VAT declarations: February to June 2025; and
• Quarterly VAT declarations: Quarter I and Quarter II of 2025.

It is important to note that the decree does not alter VAT filing obligations. Taxpayers must continue to submit VAT returns in accordance with existing deadlines.

Extension duration and revised deadlines

The extension periods are differentiated depending on the tax period, with longer deferrals granted for earlier months of the year.

Practical implications

The VAT extension allows taxpayers to temporarily retain VAT amounts collected from customers, improving working capital availability. However, enterprises should carefully manage these funds, as the deferred VAT remains fully payable once the extension period ends. Failure to plan for these payments could result in liquidity strain later in the year.

Extension of Corporate Income Tax (CIT) Provisional Payments

Scope and duration

Decree 82 provides a five-month extension for provisional CIT payments arising from:

• Quarter I of 2025; and
• Quarter II of 2025.

The extension period begins from the original statutory payment deadline under tax administration regulations.

Impact on tax planning

While the extension improves short-term cash flow, it does not change:

• CIT rates;
• Taxable income determination; or
• Final annual CIT settlement obligations.

Enterprises should ensure that deferred provisional payments are properly reflected in cash flow forecasts and internal tax provisions to avoid accumulation risks toward year-end.

VAT and PIT for Business Households and Individuals

A notable feature of Decree 82 is the extension granted to business households and individuals, a group often more exposed to income volatility.

Under the decree:

• All VAT and PIT amounts arising in 2025 for eligible business households and individuals are extended;
• The new payment deadline is 31 December 2025.

This provision provides significant flexibility for small-scale operators, allowing them to stabilise operations throughout the year without immediate tax payment pressure.

Extension of Land Rent Payments

Scope of land rent relief

Decree 82 also addresses land rent obligations, representing a vital yet often overlooked aspect of tax relief measures that holds particular significance for capital-intensive businesses reliant on manufacturing facilities or large industrial footprints. Eligible taxpayers benefiting from this provision are granted a six-month extension specifically for 50% of the annual land rent payable in 2025, corresponding to the first installment payment. This relief applies exclusively to cases where land rent is structured on an annual payment basis, providing essential cash flow support amid economic pressures while ensuring compliance with broader fiscal timelines.

Revised payment deadline

The new deadline for the extended land rent amount is 30 November 2025.

This measure particularly benefits enterprises in manufacturing, logistics, industrial parks, and real estate development, where land rent represents a substantial fixed cost.

Procedures for Applying the Extension

Single Application Principle

Taxpayers seeking relief under Decree 82 must submit a single "Request for Tax and Land Rent Extension" form that comprehensively covers all eligible taxes and periods, streamlining the process and avoiding multiple submissions.

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Submission Deadline and Methods

Eligible taxpayers are required to submit this unified request by May 30, 2025. The submission can be completed conveniently through the tax authority's official online portal for electronic filing, delivered in person at designated tax offices, or mailed by post to the relevant authority. No prior approval or notification from the tax authority is necessary, as the extension takes effect automatically upon receipt of a valid, complete request, significantly easing administrative burdens.

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Post-Submission Review

Following submission, the tax authority may conduct a review to verify eligibility. If it determines that a taxpayer does not qualify for the extension, a formal notification will be issued, requiring immediate payment of the outstanding tax amounts along with applicable late payment interest calculated in accordance with standard tax administration regulations

Key Implications for Enterprises and Foreign-Invested Companies

For enterprises operating in Vietnam, including foreign-invested companies, Decree 82 offers meaningful but temporary relief. To maximise its benefits, businesses should:

• Review eligibility carefully, particularly with respect to licensed business activities;
• Maintain strict compliance with filing deadlines despite payment extensions;
• Track deferred tax liabilities separately from operating cash;
• Coordinate between local finance teams and group-level reporting functions.

Foreign-invested enterprises should also consider the impact of deferred taxes on intercompany cash flows, dividend planning, and internal financing arrangements.

Conclusion

Decree 82/2025/NĐ-CP represents a comprehensive and carefully calibrated support measure, extending payment deadlines for VAT, CIT, PIT, and land rent across a wide spectrum of taxpayers. By prioritising liquidity relief over permanent tax concessions, the Government balances immediate business needs with long-term fiscal stability.

For enterprises and individuals operating in Vietnam, the decree provides valuable breathing room in 2025. However, the benefits can only be fully realised through disciplined tax management, accurate forecasting, and continued compliance with filing obligations. As Vietnam’s tax environment becomes increasingly sophisticated and digitally driven, measures such as Decree 82 highlight a clear policy message: flexibility in timing, but firmness in accountability.