Vietnam PIT Law Amendment (Effective July 2026) — Final Pre-Enforcement Checklist

Only about one month remains until Vietnam’s amended Personal Income Tax Law (Law No. 109/2025/QH15) takes effect on July 1, 2026. The new personal allowance (15.5M VND/month) and dependent allowance (6.2M VND/month) have already been applied to payroll since January 2026, and the implementing Decree draft has already revealed concrete additional changes to allowances and tax exemptions that companies can prepare for now.

This article serves as a follow-up to our February 2026 piece “Vietnam PIT Law Amendment July 2026: 5 Things Companies Must Prepare Now.” With enforcement just around the corner, we provide HR and accounting professionals at Japanese-affiliated companies with the latest status of sub-laws and a 12-point final checklist to verify before July 1.

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Quick Review: New 5-Tier Tax Table and Deductions

Law No. 109/2025/QH15 was passed by the National Assembly on December 10, 2025, replacing the previous Law No. 04/2007/QH12. Article 9 of the new law restructures the progressive tax brackets from 7 tiers to 5 tiers, and the threshold for the top rate (35%) has been raised from 80M VND to 100M VND.

TierMonthly taxable incomeTax rate
10 – 10M VND5%
2Over 10M – 30M VND10%
3Over 30M – 60M VND20%
4Over 60M – 100M VND30%
5Over 100M VND35%

Regarding deductions, the personal allowance has been raised from 11M VND → 15.5M VND/month, and the dependent allowance from 4.4M VND → 6.2M VND/month. These were applied retroactively to wages and salaries from January 1, 2026, so payroll calculations should already reflect them.

Five Draft-Based Changes to Prepare for Proactively

The implementing Decree draft was published by the Ministry of Finance on March 27, 2026 and went through public consultation. Regardless of when the final version is officially issued, the draft already contains concrete changes that directly affect payroll logic and internal regulations. Preparing now lets you avoid confusion immediately after enforcement.

The table below summarizes the major changes identified in the draft, followed by recommended proactive preparation actions.

ItemCurrentDraft (effective July 1, 2026)
Meal allowance (cash) cap730,000 VND/month1.2M VND/month
Voluntary pension/life insurance deduction1M VND/month3M VND/month
Severance payPartially taxableFully tax-exempt (if specified in internal rules)
Overtime/night shift allowanceConditional exemptionFully tax-exempt
Side income withholding threshold2M VND/transaction, 10M VND/year3M VND/transaction, 15M VND/year

Proactive Preparation Actions

  • Document the basis for severance pay in work rules or financial regulations so it qualifies for full tax exemption
  • Run a simulation switching overtime and night shift allowances from “premium portion only” to “fully tax-exempt” treatment
  • Configure the new caps for meal allowance and pension deductions as parameters in your payroll system, ready to switch on the effective date
  • Build a payroll setup that can be updated by configuration rather than code changes, so further adjustments after the official Decree are quick to apply

12-Point Final Checklist Before Enforcement

Below is the final checklist that Japanese-affiliated companies should complete by July 1, 2026. We recommend dividing tasks among HR, accounting, and payroll system administrators and proceeding in parallel.

No.Check itemOwner
1Confirm payroll system supports the new 5-tier tax tableSystem Admin
2Confirm new deductions (15.5M / 6.2M) are reflected (already applied since Jan)Payroll
3Update meal allowance cap to 1.2M VNDHR / Accounting
4Update voluntary pension deduction cap to 3M VNDPayroll
5Reflect 21 tax-exempt categories in internal rulesHR
6Update overtime/night shift exemption processingPayroll
7Review employment contracts, work rules, and financial regulationsHR / Legal
8Confirm CCCD (Citizen ID) integration with tax codesHR
9Review expatriate tax equalization (gross-up)Accounting
10Communicate new rules to employees (especially personal allowance changes)HR
11Update gross-up calculation formulaAccounting
12Continue monitoring official Decree/Circular publicationAll

Recommendation: Run final payroll simulations in June
It is strongly advised to run a parallel comparison between old rules and new rules using June 2026 payroll data. This allows you to identify discrepancies between system calculations and manual calculations before enforcement, minimizing the risk of incorrect withholding from July onwards.

Impact on Expatriates

For Japanese expatriate staff, the key points are as follows.

  • Residency criteria: The 183-day rule remains unchanged.
  • Tax residents: Middle-income earners (annual income roughly 360M – 1.2B VND) will see meaningful tax reductions.
  • Non-residents: 20% flat rate unchanged.
  • Gross-up calculations: With the top-rate threshold raised from 80M to 100M VND, the company’s burden for high earners is reduced.

For expatriates whose tax is borne by the company under tax equalization arrangements, the gross-up formula must be reviewed. We recommend running test calculations for several typical salary brackets in advance.

New Taxable Items (Digital Assets, Gold, etc.)

Article 3 of the new law adds the following new categories of taxable income. While these are less likely to apply directly to Japanese-affiliated manufacturers, they should be noted as future business considerations.

  • Digital asset transfers: 0.1% (already in effect under Circular 32/2026)
  • Gold bar transfers: 0.1% (from July 1, 2026)
  • .vn domain name transfers: Taxed as transfer income
  • Carbon credit transfers: Taxed as transfer income
  • E-commerce platform income: Withholding by platform

Comparison with February Article: Confirmed vs. Still Unclear

The following table summarizes the progress made between our February 2026 article and June 2026.

ItemFebruary 2026June 2026
5-tier tax tableConfirmed by lawConfirmed (unchanged)
Personal/dependent allowancesPending DecreeApplied to payroll since Jan
Meal allowance capUnknownDraft: 1.2M VND (ready to prepare)
Pension deduction capUnknownDraft: 3M VND (ready to prepare)
Severance pay exemptionUnknownDraft: fully exempt (ready to prepare)
Implementing DecreeNot yet draftedDraft published; final timing to monitor

The legal framework is clear, and the draft already reveals the practical changes that will hit payroll. The smart approach is to start preparing now based on the draft so that minor adjustments after the official Decree can be absorbed quickly.

Conclusion: Lock In Final Confirmations During June

With Vietnam’s amended PIT Law taking effect on July 1, 2026, we recommend that Japanese-affiliated companies complete the following three priorities during the month of June.

  • Payroll system parallel verification: Confirm both old and new rule calculations match expected values
  • Internal regulation updates: Document tax-exempt categories such as severance pay and meal allowances in writing
  • Continued monitoring of official sub-laws: Be ready to respond immediately when Decree and Circular are published

Build a payroll setup that can absorb further fine-tuning after the official Decree is published, while leveraging the draft content to lock in the major preparation work now. This approach minimizes disruption immediately after July 1.

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