Official Letter 3896/CT-CS: 04 conditions for FDI enterprises to be eligible for a 3-year Corporate Income Tax (CIT) exemption

Official Letter 3896/CT-CS: 04 conditions for FDI enterprises to be eligible for a 3-year Corporate Income Tax (CIT) exemption

18/06/2026

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On June 11, 2026, the Tax Department issued Official Letter 3896/CT-CS, officially guiding the policy of Corporate Income Tax (CIT) exemption for Foreign Direct Investment (FDI) enterprises that meet the conditions of small and medium-sized enterprises (SMEs).

According to the guidelines, FDI enterprises shall be exempt from CIT for 03 years from the date of issuance of their initial Enterprise Registration Certificate, provided they simultaneously satisfy the following 04 conditions:

(1) Established and registered for operation in accordance with the laws of Vietnam.

(2) Issued with the initial Enterprise Registration Certificate.

(3) Meeting the criteria for determining small and medium-sized enterprises as stipulated in the 2017 Law on Support for Small and Medium-Sized Enterprises and Decree 80/2021/ND-CP.

(4) Not falling under the cases excluded from the preferential policy, which include enterprises established from mergers, consolidations, divisions, separations, or conversions; or having elements of inheriting business operations from former enterprises as prescribed in Clause 3, Article 7 of Decree 20/2026/ND-CP.

The corporate income tax exemption does not apply to the incomes specified in Clause 3, Article 18 of the Law on Corporate Income Tax No. 67/2025/QH15.

This is a notable support policy for newly established small and medium-sized FDI enterprises in Vietnam, contributing to reducing tax costs during the initial phase of operations and promoting a more favorable business and investment environment.

Download Official Letter 3896/CT-CS

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Crowe Vietnam Team

This content has been prepared by the expert team at Crowe Vietnam, aiming to deliver valuable and practical insights to enterprises.

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