Official document No. 218/CST-TN Issued on January 27, 2026, by the Ministry of Finance, this is an important document providing guidance on the conditions for accounting for salary expenses. In this context... Corporate Income Tax Law No. 67/2025/QH15 With Decree No. 320/2025/ND-CP in effect, this document helps resolve difficulties regarding non-cash payment documents. Compliance with Official Letter No. 218/CST-TN is a mandatory condition to protect deductible expenses when settling taxes.
The central content of Official Letter No. 218/CST-TN stipulates that salaries of 5 million VND or more must be paid via bank transfer starting from December 15, 2025. This regulation aims to tighten cash flow management and ensure transparency in labor relations. Understanding the guidance in Official Letter No. 218/CST-TN will help accountants proactively manage tax risks and prepare audit documents most effectively.
Legal context for the issuance of Official Letter No. 218/CST-TN
The issuance of Official Letter No. 218/CST-TN is a result of the tax administration digitalization roadmap. Article 9 of the Corporate Income Tax Law No. 67/2025/QH15 includes the requirement for "non-cash payment documents" as a mandatory item for specific expenses.
To be more specific, Decree No. 320/2025/ND-CP sets the effective date as December 15, 2025. However, many businesses are still confused about the definition of "in-transaction payment". Official Letter No. 218/CST-TN serves as a "guide," directly answering the questions of major auditing firms and law firms.
Official document No. 218/CST-TN is based on a rigorous legal framework, including:
- Law on Corporate Income Tax No. 67/2025/QH15 on deductible expenses.
- Decree No. 320/2025/ND-CP provides guidance on the implementation of the Corporate Income Tax Law.
- Decree No. 181/2025/ND-CP provides detailed regulations on VAT.
- Decree No. 52/2024/ND-CP on non-cash payments.
Detailed analysis of Official Letter No. 218/CST-TN regarding the conditions for payroll accounting.
According to Official Letter No. 218/CST-TN, businesses need to meet three levels of conditions for salaries to be accepted as deductible expenses. If any of these factors are missing, the expense will be disqualified from being considered a reasonable expense when calculating deductions. corporate income tax.
| Criteria | The regulations are as stipulated in Official Letter No. 218/CST-TN. | Important notes |
| Applicable objects | Income from each payment of 5 million VND or more. | This includes salary, wages, and bonuses. |
| Payment methods | Bank transfer or cashless payment | According to Decree 52/2024/ND-CP |
| Time of application | From December 15, 2025 | Tax period 2025 |
| Supporting documents | Payroll, Contracts, Bank Statements | The amount of money and the recipient must match. |
General conditions for production and business operations
The salary expenses mentioned in Official Letter No. 218/CST-TN must be actual expenses incurred and directly related to business operations. Businesses must prove the presence of employees through personnel records such as contracts, time sheets, and specific work results.
Completeness of documents according to Official Letter No. 218/CST-TN
The Tax Administration Department emphasized in Official Letter No. 218/CST-TN that internal documents are insufficient. Businesses need to improve their financial regulations, salary regulations, and reward decisions. All expenses must be accounted for in the correct period to ensure compliance with the principle of matching.
The threshold is 5 million VND and the payment obligation is as per Official Letter No. 218/CST-TN.
Official document No. 218/CST-TN lowers the ceiling for cash payments of salaries from 20 million to 5 million VND. This is a decisive step aimed at increasing transparency of personal income and more effectively controlling outstanding social insurance debts.
Explanation of "installment payments" in Official Letter No. 218/CST-TN
Many accountants have questioned the practice of splitting salaries into smaller installments for cash payments. Circular No. 218/CST-TN cites Decree 320/2025/ND-CP regarding the total value of each payment. If the total amount paid to an individual in a single payment is 5 million VND or more, bank transfer is mandatory.
Risks of non-compliance with Official Letter No. 218/CST-TN
If cash payments for salaries exceeding 5 million VND are made after December 15, 2025, the tax authorities will disallow the entire expense. As evidenced by Decree No. 320/2025/ND-CP in Official Letter No. 218/CST-TN, expenses without proper payment documentation will be considered non-deductible.
Identify non-cash payment documents according to Official Letter No. 218/CST-TN
Official document No. 218/CST-TN refers to Decree 181/2025/ND-CP to define valid documents. This creates consistency between corporate income tax and value-added tax, helping accountants to perform their duties uniformly and minimize errors in tax declaration.
Accepted payment methods
Based on Official Letter No. 218/CST-TN, the following forms are considered valid:
- Transferring funds from a company account to an employee's account.
- Payment via business-identified e-wallet.
- Legitimate forms of debt offsetting require a written agreement.
Please note that cash deposits should be made into the account as per Official Letter No. 218/CST-TN.
Official document No. 218/CST-TN clarifies that depositing cash into the seller's account is not considered a non-cash payment. Businesses must execute payment orders from the company account instead of directly depositing cash into employees' cards.
Instructions for handling transitions according to Official Letter No. 218/CST-TN
Since Circular No. 218/CST-TN takes effect in mid-December 2025, businesses need to pay attention to allocating expenses for the 2025 tax period. This is a transitional period, requiring accuracy in separating documents according to the old and new regulations.
Processing November 2025 salaries
If November salaries are paid before December 15, 2025, the old regulations may still apply. However, all payment orders from December 15, 2025, must be strictly compared with Official Letter No. 218/CST-TN to ensure the validity of deductible expenses.
Updated salary regulations according to Official Letter No. 218/CST-TN
Businesses should add payment method clauses to their contracts and financial regulations. Clearly stating "salaries paid via bank account" will be compelling evidence of compliance with Circular No. 218/CST-TN during tax audits.
Optimal payroll cost management solution
Implementing Circular No. 218/CST-TN requires a professional human resource management system. Accountants need to ensure consistency between payroll records, personal income tax returns, and bank statements. Errors can lead to tax arrears and penalties for late payment.
Businesses should proactively review their records, ensuring all payment procedures comply with the guidelines in Official Letter No. 218/CST-TN. Strict control from the payroll preparation stage will help minimize the risk of expenses being disallowed during tax settlement.
Conclude
Official document No. 218/CST-TN is a significant milestone in increasing transparency in business expenses. Strictly implementing the guidelines for cashless salary payments exceeding 5 million VND from December 15, 2025, helps businesses protect their interests and avoid legal risks.
If you encounter difficulties in setting up a documentation system that complies with Official Letter No. 218/CST-TN, please contact MAN – Master Accountant Network. We provide auditing services, tax accounting, settlement and tax reporting Complete package. MAN is committed to helping businesses optimize costs and strictly comply with the latest legal regulations.
Service contact information at MAN – Master Accountant Network
- Address: No. 19A, Street 43, Tan Thuan Ward, Ho Chi Minh City
- Mobile/Zalo: 0903 963 163 – 0903 428 622
- Email: man@man.net.vn
Content production by: Mr. Le Hoang Tuyen – Founder & CEO MAN – Master Accountant Network, Vietnamese CPA Auditor with over 30 years of experience in Accounting, Auditing and Financial Consulting.
Frequently Asked Questions about Official Letter No. 218/CST-TN
Official document No. 218/CST-TN is based on the actual payment value. If the amount transferred to the employee after deducting insurance and taxes is 5 million VND or more, bank transfer is mandatory.
Yes. According to Official Letter No. 218/CST-TN, salaries and other payables are subject to regulation. If the total amount of one-time payments reaches 5 million VND, you must make the payment using non-cash methods.
Official document No. 218/CST-TN does not provide for an exemption in this case. Businesses need to instruct employees to use digital banking or e-wallets to ensure that expenses are deductible according to regulations. If the net salary is under 5 million VND but the gross salary is over 5 million VND, does it have to be transferred via bank transfer?
Are the allowances added to the 5 million amount?
How do businesses in remote areas without access to banks operate?
