From July 1, 2026, taxpayers subject to corporate income tax when allocating tax must apply the provisions in Circular 89/2026/TT-BTC on the declaration, payment and finalization of tax.
1. Business activity with fixed assets and real estate
Declaration and payment
- Enterprises are not eligible for tax reduction under the corporate income tax incentive regime.
- Enterprises must declare and pay corporate income tax according to the provisions in Item b.1, Clause 4, Article 21 of Circular 89/2026/TT-BTC and are not subject to the tax on behalf of organizations and individuals that have fixed assets and real estate.
Finalization
- Enterprises subject to corporate income tax when allocating tax are required to declare their final tax settlement for the fiscal year, in accordance with the provisions on tax finalization for self-determined tax payable for the second and subsequent cases.
- Enterprises subject to corporate income tax are required to determine provisional tax payable and declare seasonal tax installments, in accordance with the provisions of Article 15 of the Law on Tax Administration 2025 and Article 42 of Circular 89/2026/TT-BTC.
2. Business activity with no fixed assets
Declaration and payment
- Enterprises are not subject to the tax reduction under the corporate income tax incentive regime when declaring and paying corporate income tax according to the provisions in Item b.2, Clause 4, Article 21 of Circular 89/2026/TT-BTC.
- Tax payable is determined according to the withholding method for non-resident enterprises with income from business activities.
Finalization
- Enterprises subject to corporate income tax when allocating tax are required to declare provisional tax and pay tax installments for the fiscal year, in accordance with the provisions on provisional tax for self-determined tax payable for the second and subsequent cases.
- Enterprises must declare final tax settlement for the fiscal year, in accordance with the provisions on tax finalization for self-determined tax payable for the second and subsequent cases.
- In case of a decrease in provisional tax payable or an increase in actual tax payable compared to the previous period, the enterprise must adjust the tax declaration according to the provisions of Article 15 of the Law on Tax Administration 2025 and Article 42 of Circular 89/2026/TT-BTC.
Note
- Enterprises with small and medium business scale, no fixed assets, and no revenue from real estate business are not subject to provisional tax declaration and payment.
- In case of a decrease in provisional tax payable or an increase in actual tax payable, the enterprise must adjust the tax declaration according to the provisions of Article 15 of the Law on Tax Administration 2025 and Article 42 of Circular 89/2026/TT-BTC.
3. FOR ENTERPRISES WITH PRODUCTION FACILITIES LOCATED IN MULTIPLE PROVINCES
Declaration and provisional payment of CIT (quarterly)
- Taxpayers are not required to submit quarterly CIT declaration dossiers. However, they must determine the provisional CIT amount for each quarter in accordance with Point b.3, Clause 4, Article 21 of Circular 89/2026/TT-BTC and pay the tax to the state budget for each province where there is a production facility, including provinces where the dependent unit is entitled to CIT incentives.
- The taxpayer may establish a separate allocation for each province according to its production facility.
Tax settlement (finalization)
- Taxpayers shall file a unified CIT finalization for all production and business activities of the production facilities at the head office and pay the allocated tax for each province where there is a production facility.
- For activities entitled to CIT incentives, taxpayers shall file tax finalization with the directly managed tax authority, determine the payable CIT for the incentive-eligible activities and pay the tax to the state budget for each province where the incentive unit is located.
- If the provisional tax paid is less than the tax payable according to the finalization, the taxpayer must pay the shortfall to each province.
- If the provisional tax paid is higher than the tax payable according to the finalization, the excess is considered tax overpaid and handled in accordance with Article 15 of the 2025 Tax Administration Law and Article 42 of Circular 89/2026/TT-BTC.
4. FOR HYDROPOWER PLANTS LOCATED IN MULTIPLE PROVINCES
Declaration and provisional payment of CIT (quarterly)
- Taxpayers are not required to submit quarterly CIT declaration dossiers. However, they must determine the provisional CIT amount for each quarter in accordance with Point b.4, Clause 4, Article 21 of Circular 89/2026/TT-BTC.
- The provisional CIT is paid to the state budget for each province where there is a hydropower plant.
Tax settlement (finalization)
- Taxpayers shall file a unified CIT finalization for all production and business activities at the head office and pay the allocated tax for each province where there is a hydropower plant.
- If the provisional tax paid is less than the tax payable according to the finalization, the taxpayer must pay the shortfall to each province.
- If the provisional tax paid is higher than the tax payable according to the finalization, the excess is considered tax overpaid and handled in accordance with Article 15 of the 2025 Tax Administration Law and Article 42 of Circular 89/2026/TT-BTC.
