Circular 32/2026/TT-BTC on VAT, Corporate Income Tax, and Personal Income Tax for Crypto Asset Transactions

Signed by: MINISTRY OF FINANCE Organization: 28 Tran Hung Dao Signing Time: 27/03/2026 17:01:46 +07:00

MINISTRY OF FINANCE SOCIALIST REPUBLIC OF VIETNAM Independence - Freedom - Happiness

No. 32/2026/TT-BTC Hanoi, March 27, 2026

CIRCULAR Guiding Value Added Tax, Corporate Income Tax, and Personal Income Tax on Transactions, Transfers, 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 and supplemented 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 and supplemented by Law No. 26/2012/QH12, Law No. 71/2014/QH13, and Law No. 56/2024/QH15;

Pursuant to Government Decree No. 320/2025/NĐ-CP detailing certain articles and measures for the organization and guidance of the implementation of the Law on Corporate Income Tax;

Pursuant to Government Decree No. 181/2025/NĐ-CP detailing certain articles of the Law on Value Added Tax, as amended and supplemented by Decree No. 359/2025/NĐ-CP;

Pursuant to Government Decree No. 65/2013/NĐ-CP detailing certain articles of the Law on Personal Income Tax and the Law amending and supplementing certain articles of the Law on Personal Income Tax, as amended and supplemented by Decree No. 12/2015/NĐ-CP;

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

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

*At the request of the Director of the Department of Tax, Fee, and Levy Management and Supervision;

The Minister of Finance issues the Circular guiding Value Added Tax, Corporate Income Tax, and Personal Income Tax on transactions, transfers, and business of crypto assets.*

---

2

Article 1. Scope of Regulation

This Circular guides Value Added Tax, Corporate Income Tax, and Personal Income Tax, and the timing for determining revenue and income for transactions, 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. Subjects of Application

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

Article 3. Value Added Tax Policy

1. The transfer and business of crypto assets are subject to exemption from Value Added Tax.

2. For activities not specified in Clause 1 of this Article, the provisions of the law on Value Added Tax shall apply.

Article 4. Corporate Income Tax Policy

1. Investors that are organizations established and operating in accordance with Vietnamese law and deriving income from crypto asset transfer activities are subject to Corporate Income Tax at a rate of 20%, except for cases specified in Clause 2 and Clause 3 of Article 10 of the Law on Corporate Income Tax No. 67/2025/QH15.

Taxable income from crypto asset transfer activities in the period is determined by the selling price of the crypto assets minus the purchase price of the transferred crypto assets and related costs associated with the transfer, supported by invoices and documents as prescribed.

2. Enterprises that are organizations providing crypto asset services as specified in Clause 3 of Article 3 of Resolution No. 05/2025/NQ-CP and deriving income from providing crypto asset services are subject to Corporate Income Tax at a rate of 20%, except for cases specified in Clause 2 and Clause 3 of Article 10 of the Law on Corporate Income Tax No. 67/2025/QH15.

3. Investors that are organizations established in accordance with the laws of foreign countries and conducting crypto asset transfers through organizations providing crypto asset services are subject to Corporate Income Tax at a rate of 0.1% on the revenue from each transfer transaction.

Article 5. Personal Income Tax Policy

Investors that are individuals (regardless of whether they are residents or non-residents)

---

3

conducting crypto asset transfers through organizations providing crypto asset services are subject to Personal Income Tax at a rate of 0.1% on the transfer price of each transaction.

Article 6. Timing for Determining Revenue and Income

The timing for determining revenue and income for the transfer of crypto assets shall be implemented in accordance with the provisions of the law on Corporate Income Tax, the law on Personal Income Tax regarding the timing for determining revenue and income for the transfer of securities, and the law on crypto assets.

Article 7. Effectiveness

1. This Circular takes effect from March 27, 2026, and is implemented according to the pilot implementation period specified in Clause 2 and Clause 3 of Article 18 of Resolution No. 05/2025/NQ-CP, or until tax policies for the crypto asset market in Vietnam are specified in Clause 9 of Article 4 of Resolution No. 05/2025/NQ-CP.

2. Matters not guided in this Circular shall be implemented in accordance with the provisions of current tax law.

Distribution:

• Central Secretariat of the Communist Party of Vietnam;
• Prime Minister, Deputy Prime Ministers;
• Central Secretariat Office and Party Committees;
• Office of the General Secretary;
• National Assembly Office;
• Government Office;
• Office of the President;
• National Council and Committees of the National Assembly;
• Supreme People's Procuracy;
• Supreme People's Court;
• State Audit Office;
• Vietnam Fatherland Front Central Committee;
• Central agencies of mass organizations;
• Ministries, ministerial-level agencies, and agencies under the Government;
• People's Councils and People's Committees of provinces and centrally run cities;
• Provincial and centrally run city Departments of Finance;
• Provincial and centrally run city Tax Departments;
• Department of Document Inspection and Legal Implementation Organization, Ministry of Justice;
• Official Gazette;
• National legal database;
• National legal portal;
• Government Electronic Portal;
• Ministry of Finance Electronic Portal;
• Units under the Ministry of Finance;
• Store: VT, CST (100 copies).

ON BEHALF OF THE MINISTER DEPUTY MINISTER

(Signed and stamped)

Cao Anh Tuan