VCI Legal – May 20, 2026

On March 27, 2026, the Ministry of Finance issued Circular 32/2026/TT-BTC guiding value-added tax, corporate income tax and personal income tax on crypto asset transactions, transfers and trading (“Circular 32”).  

Circular 32 will take effect from the date of promulgation and during the pilot period of the crypto asset market under Resolution 05/2025/NQ-CP (within 5 years from 09/09/2025), or until there is an official and comprehensive tax policy framework for the crypto asset market in Vietnam.  

Key takeaways: 

• Enterprises must pay Corporate Income Tax (CIT) at rates ranging from 15%-20% depending on revenue; foreign enterprises pay 0.1% of revenue/transaction; 

• Transfers of crypto assets that are not subject to Value Added Tax (VAT); 

• Resident and non-resident individuals both pay Personal Income Tax (PIT) at 0.1% of the transfer/transaction value; 

• Enterprises need to comply with the correct time of determining revenue, accounting transparently, and keeping valid documents. 

1. Main points 

Subjects of application  

Circular 32 regulates organizations and individuals engaged in transactions, transfers and business activities related to crypto assets, including: 

• Organizations providing crypto asset services; 

• Issuers of crypto assets;  

• Vietnamese and foreign organizations and individuals investing in crypto assets and operating in the crypto asset market 

• Agencies, organizations and individuals involved in the offering, issuance, trading and state management of the crypto asset market in Vietnam. 

Corporate Income Tax (CIT) Policy  

Enterprises engaged in the transfer of crypto assets or the provision of crypto asset services must submit CIT based on taxable income multiplied by the tax rate as follows:

• 15% for enterprises with revenue of less than 3 billion VND/year; 

• 17% for enterprises with revenue from over 3 billion to 50 billion VND/year; 

• 20% for the rest of the cases 

Taxable income from the transfer of crypto assets is calculated as the selling price minus the purchase price and the transfer expenses of valid invoices and documents. In addition, foreign enterprises that generate income from the transfer of crypto assets through service providers will submit a CIT equal to 0.1% of the transfer revenue per transaction. 

Value Added Tax (VAT) policy 

For the transfer and trading of crypto assets, enterprises do not need to pay VAT, while other activities still have to fulfill tax obligations as prescribed.

Investors directly benefit from this regulation since transaction costs decrease, market liquidity increases, and opportunities to access capital flows are wide. This not only creates a competitive advantage for businesses in the pilot period but also lays the foundation for the sustainable development of the digital economy. 

Personal Income Tax (PIT) Policy 

For individuals, whether resident or not, when making a transaction to transfer a crypto asset through a service provider, they must pay a PIT of 0.1% of the transfer price per transaction. It should be noted that transactions through unlicensed service systems or through unrecognized platforms will not be eligible for this incentive.

Time to determine revenue and income  

The time for determining revenue and income from the transfer of crypto assets is applied in accordance with the provisions of the law on corporate income tax and personal income tax for securities transfer:

• For PIT, the time to determine revenue is when the transaction is completed in accordance with the law.

• For CIT, the time of determining revenue is the time of transfer. 

This regulation requires enterprises to develop a clear accounting process, keep sufficient documents to prove the time of transaction, and at the same time make a reasonable transfer plan to optimize tax costs and ensure compliance with the law. 

Procedures for declaring and paying taxes on crypto assets 

According to current regulations, enterprises providing crypto asset services are obliged to8: 

• Declare and pay VAT according to the prescribed form; determine and submit quarterly provisional CITs;  

• Deduct and pay taxes on behalf of foreign organizations and individuals upon successful transactions; 

• Manage accounts, store transaction data, provide information to tax authorities when required and ensure that the information technology system meets management requirements. 

2. Solutions and Actions 

Circular 32 sets out regulations that directly affect businesses participating in trading, transferring and trading in crypto assets. Businesses need to seriously comply with regulations, because any delay or error in tax declaration, deduction and payment can lead to legal risks, unexpected costs and loss of competitive advantage in the pilot period. 

The Tax & Legal team at VCI Legal is implementing the following package of solutions to support crypto asset trading clients: 

• Legal and tax advice related to CIT, PIT, VAT; 

• Support tax declaration, deduction and payment in accordance with regulations; 

• Develop the process of accounting and keeping valid documents; 

• Advising on trading strategies to optimize tax costs; 

• Assist in managing data and IT systems that comply with tax authority requirements. 

About VCI Legal:

VCI Legal is an award-winning business law firm in Vietnam with a wide range of legal and corporate services, among other things, corporate, banking & finance, tax, labor & HR, real estate and dispute resolution with special focus on international investment disputes, We also offer our specialized type of service called “In-House Counsel Service” with the aim of assisting our clients in dealing with all types of internal and external issues arising from their day-to-day operations and business activities. With our offices in both Hanoi and Ho Chi Minh City, we have a tremendous depth of experience in providing well-reasoned and comprehensive legal advice to not only multinationals and Fortune 500 companies, but also small and medium enterprises.

Our professional team comprises one of the leading law firms in Vietnam with service quality highly recommended and acknowledged by international legal service reviewers such as: The Legal 500, AsiaLaw Profiles, IFLR, KPMG’s Tax Directors’ Handbook, Acquisition International, ACQ Global, Global Law Experts, Finance Monthly, and Chambers & Partners.

For many years, VCI Legal has been ranked among the top law firms in Vietnam for corporate, finance, insurance, taxation, employment, intellectual property and investment. With a “Can Do Attitude” combined with a “Know How” capacity, our firm is big enough to provide comprehensive legal support for any in-house legal matters, yet small enough to care about each of our clients. We undertake each engagement with the mindset of a long-term relationship, with the will to give whatever it takes to understand and fulfill your needs.

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