Paying salaries in cash from 5 million VND is at risk of being eliminated from expenses
Just a small mistake in the form of paying salaries from the threshold of 5 million VND, businesses may have their entire reasonable costs eliminated by the tax authorities.
Businesses "horrified" by non-cash payment regulations
Mr. N.V.C expressed confusion when approaching Decree No. 320/2025/ND-CP just issued at the end of 2025. Specifically, at point c, clause 1, Article 9 of this Decree, it is stipulated that expenses worth 5 million VND or more must have non-cash payment vouchers to be included in valid expenses.
As the drafting agency, please clarify: Is the salary and wage expenditure each time paid from 5 million VND or more mandatory to be transferred or use other non-cash forms to be calculated as a deductible expense when determining corporate income taxable income?" - Mr. C. raised the issue. This is also a common concern of many units that still maintain the habit of paying salaries directly in cash to employees.
Warning about excluding costs when the payment method is incorrect
Answering this question, the Quang Tri Provincial Tax Department has responded based directly on current legal documents. Specifically, according to the provisions of point c, clause 1, Article 9 of Decree No. 320/2025/ND-CP:
Expenses with non-cash payment vouchers for cases of buying and selling goods, services and other payments each time with a value of 05 million VND or more". This voucher must be made in accordance with the provisions of the law on value-added tax.
Based on the above, the Tax Department determined: In case of paying salaries and wages to employees each time from 05 million VND or more without non-cash vouchers as prescribed, the deductible expenses are not recorded when determining corporate income taxable income.
Thus, if a business still intentionally or unintentionally spends cash from 5 million VND or more per time on employees, this expense will "disappear" from the list of deductible expenses when determining corporate income tax (CIT) taxable income. This means that the amount of CIT that the business has to pay will unfortunately increase sharply.
Applicable immediately for the 2025 tax period: No exceptions
Regarding the application time, Decree No. 320/2025/ND-CP takes effect from the date of signing and promulgation. In particular, the determination of the application time for the corporate income tax period starts from 2025.
Regarding the regulation on non-cash payment documents in point c, clause 1, Article 9, it is applied immediately from the time this Decree takes effect (December 15, 2025). The tax authority requests Mr. C. as well as businesses to compare the actual situation to properly implement legal regulations, avoiding errors that cause financial damage to the unit.
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