On 15 January 2026, the Government issued Decree No. 20/2026/ND-CP, providing detailed regulations and guidelines for the implementation of Resolution No. 198/2025/QH15 on specific mechanisms and policies for private sector development.

Decree 20/2026/ND-CP is expected to have a profound impact on the business community, household businesses, and investors in the coming period. It introduces a synchronized incentive framework encompassing taxation, land use, science and technology, digital transformation, and human resource training. Below are the critical points that enterprises should closely monitor during the implementation and application process.

1. Advantages treat tax collect import rack profession

The CIT exemption and reduction policies apply to three primary categories of entities, with specific regulations as follows:

Category 1: Startups and Support Organizations

• Eligibility: Innovative startup investment fund management companies, innovative startups, and intermediary organizations supporting innovative startups.
• Incentive Rates:

+  Tax Exemption: 02 years.
+ Tax Reduction: 50% reduction of the tax payable for the subsequent 04 years.

• Application Period: The incentive period is calculated consecutively from the first year the enterprise generates taxable income. If the enterprise has not generated taxable income within the first 03 years (from the year of generating revenue), the tax exemption/reduction period shall commence from the fourth year.
• Accounting Requirements: Enterprises must maintain separate accounting records for income derived from eligible incentive activities. In cases where income cannot be accounted for separately, it must be allocated based on the ratio of revenue or expenses of the incentive activities to the total revenue or total expenses of the enterprise.

Category 2: Capital Investment Enterprises (Institutional Investors)

• Incentives: 100% CIT exemption on income derived from the transfer of shares, capital contributions, or capital contribution rights in innovative startups.
• Exclusions: This incentive does not apply to the transfer of shares in public companies, listed organizations, or entities registered for securities trading. In the event of a sale of a single-member limited liability company (LLC) associated with real estate, tax shall be calculated based on real estate transfer activities.

Category 3: Newly Established Small and Medium Enterprises (SMEs)

• Incentives: CIT exemption for 03 consecutive years, commencing from the date of the first issuance of the Enterprise Registration Certificate (ERC).
• Exclusionary Conditions: This incentive does not apply to enterprises formed through mergers, acquisitions (M&A), divisions, separations, or conversion of legal forms. Furthermore, it excludes new enterprises where the owner or manager previously held a leadership position in a dissolved entity within the last 12 months.

General Provisions for Enterprises:

• In cases where an enterprise qualifies for multiple incentive schemes simultaneously, it is entitled to select the most favorable incentive rate.
• If the initial tax period is less than 12 months, the enterprise may choose to apply the incentive for that period or register to commence the incentive from the subsequent tax period.

2. Personal Income Tax (PIT) Incentives

The PIT incentive policies focus on individual investors and high-quality human resources.

For Individual Investors:

• Incentives: 100% PIT exemption on income derived from the transfer of capital contributions, shares, or capital contribution rights in innovative startups.
• Exclusions: This incentive does not apply to the transfer of shares in public/listed companies or the sale of private enterprises associated with real estate.

For Experts and Scientists:

• Eligibility: Experts and scientists working at innovative startups, R&D centers, and intermediary organizations supporting startups.
• Incentives (Applicable to wages and salaries):

+ 100% Tax Exemption: For 02 consecutive years (24 months) commencing from the date the income is generated.
+ 50% Tax Reduction: For the subsequent 04 years (48 months).
+ Calculation Method: If an individual has multiple sources of income, the tax exemption/reduction shall be calculated based on the ratio of eligible incentive income to the total taxable income within the period.

3. Support for Access to Land and Business Premises

3.1 Support for Infrastructure Investment and Land Fund Utilization

• Disclosure Responsibility: Provincial People’s Committees are required to publicly disclose the principles and criteria for investment support, as well as the specific land areas within industrial parks and technology incubators designated for prioritized entities (private high-tech enterprises, SMEs, and innovative startups).

• Financial Principles: Infrastructure developers shall not include state financial support in the total investment capital of the infrastructure project. However, they remain responsible for the upkeep and maintenance of these works.

• Prioritization Period: Land funds designated for prioritized entities are determined for each specific period. If these areas remain unleased by prioritized entities after 02 years from the date of infrastructure completion, the developer is entitled to lease the land to other enterprises.

3.2 Reimbursement Mechanism for Reduced Sublease Rentals

This mechanism involves the State reimbursing infrastructure developers for the rental amounts they have discounted for eligible lessees.

• Beneficiaries of Rental Reductions (Supported Enterprises): Including (private) high-tech enterprises, Small and Medium Enterprises (SMEs), and innovative startups.
• Conditions for Developer Reimbursement: Maintaining a designated land fund for prioritized entities; Having executed contracts clearly specifying the discounted price and having received payments from the lessees; Submitting a reimbursement request within 12 months from the date of the lessee’s payment.

Methods of Reimbursement:

• Offsetting: The amount is deducted from the land rental obligations that the developer is required to pay to the State.
• Direct Refund: If the reduction amount exceeds the financial obligations, or if the developer has already fully paid or is exempt from land rent, the State Budget shall issue a direct refund.
• Procedures: Developers submit a dossier to the Department of Finance. The Department of Finance appraises the dossier (within 07 working days) and reports to the Provincial People’s Committee to issue a decision (within 03 working days), enabling the State Treasury or Tax Authority to execute the refund or offset.

3.3 Provisions on the Recovery of Financial Support

Enterprises that have benefited from land rental reductions are required to reimburse the State Budget in the following instances:

• Legal Violations: In the event of investment project termination or land recovery due to violations of the law (reimbursement must be completed within 01 month).
• Unauthorized Transfer: Transferring land use rights to entities that do not qualify for support (reimbursement must be completed within 01 month from the date of contract execution).

Fraud and Non-compliance: If inspections or audits reveal that the enterprise was not an eligible beneficiary, the enterprise must reimburse the principal amount plus late payment interest.

3.4 Support for Leasing Public Houses and Land Assets

• Eligibility: Small and Medium Enterprises (SMEs), supporting industry enterprises, and innovative enterprises.
• Forms of Support: Eligible entities may lease houses and land (non-residential public assets) through the price posting method or benefit from rental reductions.
• Implementation: Provincial People’s Committees are responsible for promulgating the list of assets, support levels, and specific procedures tailored to local practicalities.

4. Financial Support for Research & Development (R&D)

• Establishment of Science and Technology Development Funds: Enterprises are permitted to appropriate up to 20% of their taxable Corporate Income Tax (CIT) income to establish a Fund for Science, Technology, Innovation, and Digital Transformation.

• Double Deduction of R&D Expenses: When determining taxable CIT income, actual expenditures incurred for scientific research and technological development activities are deductible at 200% of their actual value.

• Supply Chain Training Support: Large enterprises are entitled to treat expenditures related to the training and re-training of human resources for SMEs within their supply chain as deductible expenses (based on formal cooperation contracts).

5. Provision of Free Digital Platforms and Accounting Software

The State provides direct digital transformation tools to vulnerable groups, including small enterprises, micro-enterprises, household businesses, and individual business households.

6. Free Training on Management and Accounting

• Support Level: The State budget provides 100% subsidies for the total cost of training courses.
• Curriculum: Corporate governance, including accounting management, taxation, and human resources (HR).
• Beneficiaries: Micro-enterprises, small enterprises, household businesses, and individual business households.
• Procedures:

+ Implementation shall follow the framework of Decree No. 80/2021/ND-CP, with the updated support rate of 100%.

+  Household businesses and individual business households shall register their training requirements via a Declaration Form (template provided in Appendix III of this Decree).

Conclusion

Decree No. 20/2026/ND-CP presents significant opportunities for enterprises and investors. However, these incentives come with stringent requirements for eligibility, documentation, and tax-accounting compliance. Proactively grasping the regulations, reviewing operational models, and standardizing accounting practices from the outset will enable businesses to maximize available incentives while mitigating legal risks. Enterprises are advised to regularly update themselves on local implementation guidelines and consult with professional experts when applying these new incentive policies.