On December 26, 2025, the Department of Tax Policy Management and Supervision issued Official Letter No. 2759/CST-GTGT to clarify tax obligations related to foreign currency trading activities of enterprises during business operations.
1. Income from foreign currency sales is subject to Corporate Income Tax
- Income from foreign currency sales (excluding credit activities of credit institutions) is classified as other income and is subject to corporate income tax.
- Taxable income is determined as the difference between proceeds from foreign currency sales and the purchase price or cost of the sold foreign currency at the time the income arises, in accordance with tax regulations.
(According to the Law on Corporate Income Tax and Decree 320/2025/ND-CP)
2. Exchange rate differences are not subject to Value-Added Tax (VAT)
In cases where manufacturing, trading, or service enterprises (other than credit institutions or licensed foreign exchange agents) earn foreign currency revenue from abroad (export of goods, provision of services, or foreign-currency payments received) and sell such foreign currency to commercial banks:
- Exchange rate differences arising from such transactions are not subject to VAT;
- Enterprises are not required to issue VAT invoices for foreign currency sales, as this activity is not considered the sale of goods or provision of services.
(Law on Value Added Tax No. 48/2024/QH15 and Decree 123/2020/ND-CP amended by Decree 70/2025/ND-CP)
(According to Official Letter No. 2759/CST-GTGT dated December 26, 2025)
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