Circular No. 32/2026/TT-BCT on guidance on value added tax, corporate income tax, and personal income tax for trading, transfer, and business of crypto assets

CIRCULAR

ON GUIDANCE ON VALUE ADDED TAX, CORPORATE INCOME TAX, AND PERSONAL INCOME TAX FOR TRADING, TRANSFER, AND BUSINESS OF CRYPTO ASSETS

Pursuant to the Law on Corporate Income Tax No. 67/2025/QH15;

Pursuant to the Law on Value Added Tax No. 48/2024/QH15, amended by Law No. 90/2025/QH15 and Law No. 149/2025/QH15;

Pursuant to the Law on Personal Income Tax No. 04/2007/QH12, amended by Law No. 26/2012/QH12, Law No. 71/2014/QH13 and Law No. 56/2024/QH15;

Pursuant to Decree No. 320/2025/ND-CP of the Government on elaboration and measures to organize and provision guidance on the implementation of the Law on Corporate Income Tax;

Pursuant to Decree No. 181/2025/ND-CP of the Government on elaboration of the Law on Value Added Tax, amended by Decree No. 359/2025/ND-CP;

Pursuant to Decree No. 65/2013/ND-CP of the Government on elaboration of the Law on Personal Income Tax and Law amending the Law on Personal Income Tax, amended by Decree No. 12/2015/ND-CP;

Pursuant to Resolution No. 05/2025/NQ-CP of Government on the pilot implementation of the crypto asset market in Vietnam;

Pursuant to Decree No. 29/2025/ND-CP of the Government on the functions, tasks, powers and organizational structure of the Ministry of Finance, amended by Decree No. 166/2025/ND-CP;

At the request of Director of the Tax Policies, Fees and Charges Supervisory Agency;

The Minister of Finance hereby issues a Circular on guidance on value-added tax (VAT), corporate income tax (CIT), and personal income tax (PIT) for trading, transfer, and business of crypto assets.

Article 1. Scope

This Circular provides guidance on VAT, CIT, and PIT, as well as the timing of revenue and income determination for trading, transfers, and business of crypto assets in accordance with Resolution No. 05/2025/NQ-CP dated September 9, 2025, of the Government on the pilot implementation of the crypto asset market in Vietnam.

Article 2. Regulated entities

This Circular applies to relevant organizations and individuals within the scope specified in Article 1 of this Circular.

Article 3. VAT policies

1. The transfer and business of crypto assets are not subject to value-added tax.

2. For activities not specified in Clause 1 of this Article, the provisions of the laws on VAT shall apply.

Article 4. CIT policies

1. Investors that are organizations established and operating under Vietnamese law and have income from the transfer of crypto assets are subject to corporate income tax at a rate of 20%, except for cases specified in Clauses 2 and 3 of Article 10 of the Law on CIT No. 67/2025/QH15.

Taxable income from the transfer of crypto assets in the period is determined by the selling price of the crypto asset minus the purchase price of the transferred crypto asset and related transfer expenses with invoices and supporting records as prescribed.

2. Enterprises that are crypto asset service providers specified in Clause 3 of Article 3 of Resolution No. 05/2025/NQ-CP and have income from providing crypto asset services are subject to corporate income tax at a rate of 20%, except for cases specified in Clauses 2 and 3 of Article 10 of the Law on CIT No. 67/2025/QH15.

3. Investors that are organizations established under foreign law and whose operations involve transferring crypto assets through crypto asset service providers are subject to corporate income tax at a rate of 0,1% on the revenue from each transfer.

Article 5. PIT policies

Investors who are individuals (regardless of whether they are resident or non-resident) engaging in the transfer of crypto assets through crypto asset service providers are subject to PIT at a rate of 0,1% on the transfer price for each transaction.

Article 6. Time of determination of revenue, income

The time of determination of revenue and income from the transfer of crypto assets shall comply with of the Law on CIT, the Law on PIT on the time of revenue and income determination for securities transfers, and laws on crypto assets.

Article 7. Effect

1. This Circular comes into force from March 27, 2026 and shall be implemented according to the pilot implementation period specified in Clauses 2 and 3 of Article 18 of Resolution No. 05/2025/NQ-CP or until a tax policy for the crypto asset market in Vietnam is issued as specified in Clause 9 of Article 4 of Resolution No. 05/2025/NQ-CP.

2. For content not specified in this Circular, the provisions of the applicable tax laws shall apply./.