{"id":3548,"date":"2025-10-02T17:03:48","date_gmt":"2025-10-02T10:03:48","guid":{"rendered":"https:\/\/thue.man.net.vn\/?p=3548"},"modified":"2026-04-22T12:01:47","modified_gmt":"2026-04-22T05:01:47","slug":"thue-nha-thau-doi-voi-lai-vay-nuoc-ngoai","status":"publish","type":"post","link":"https:\/\/thue.man.net.vn\/en\/thue-nha-thau-doi-voi-lai-vay-nuoc-ngoai\/","title":{"rendered":"Contractor tax on foreign loan interest 2025: Draft proposes doubling the corporate income tax rate."},"content":{"rendered":"

Contractor tax on foreign loan interest is an important issue that Vietnamese businesses borrowing capital from foreign organizations, banks, or investors need to understand. According to current regulations, Foreign loan interest is certainly subject to contractor tax.<\/strong>. Specifically, the corporate income tax rate currently applied to interest on loans is... 5%<\/strong> as stipulated in Clause 3, Article 12 of Decree 320\/2025.<\/p>\n

However, businesses should take special note: From October 1, 2025, the corporate income tax rate on interest payments to foreign contractors may change. increased from 5% to 10%<\/strong> According to the draft Decree guiding the Corporate Income Tax Law No. 67\/2025 (which is not yet in effect).<\/p>\n

This article will provide a detailed analysis of the new draft regulations on contractor tax for foreign loan interest, helping businesses stay informed about changes and optimize financial costs. For more information on current regulations, please refer to the original article at: Contractor tax on foreign loan interest<\/a>.<\/p>\n

Corporate income tax rate on foreign loan interest<\/b><\/h2>\n

Understanding corporate income tax rate<\/a> Foreign loan interest is very important for businesses to estimate financial costs and fulfill tax obligations on time. According to the draft Decree guiding the Law Corporate Income Tax<\/a> According to Circular No. 67\/2025, the currently applied tax rate of 5% will be adjusted to 10% from October 1, 2025 (expected). The table below compares the old and new tax rates, scope of application, effective date, and direct impact on the cost of borrowing for businesses, helping businesses fully understand the information before making interest payments to foreign contractors.<\/span><\/p>\n\n\n\n\n\n\n\n\n
Summary table of corporate income tax rates on foreign loan interest<\/b><\/caption>\n
Content<\/b><\/td>\nDetails<\/b><\/td>\n<\/tr>\n
Current tax rate (applicable)<\/span><\/td>\n5% for loan interest paid to foreign contractors (before October 1, 2025).<\/span><\/td>\n<\/tr>\n
Proposed tax rate (not yet implemented)<\/span><\/td>\n10% for loan interest paid to foreign contractors (from October 1, 2025) according to the draft Decree guiding the Corporate Income Tax Law 67\/2025.<\/span><\/td>\n<\/tr>\n
Scope of application<\/span><\/td>\nMost interest payments are made to foreign lenders, including banks, international credit institutions and foreign investors.<\/span><\/td>\n<\/tr>\n
Effective date<\/span><\/td>\nOctober 1, 2025, subject to transitional provisions and implementation guidance in the Decree.<\/span><\/td>\n<\/tr>\n
Impact on business<\/span><\/td>\nIncreasing the tax rate from 5% to 10% will increase financial costs, especially for large or long-term loans, directly affecting financial planning and borrowing cost estimates.<\/span><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

Cases of contractor tax exemption for foreign loan interest<\/b><\/h2>\n

Some special cases allow businesses to exempt or reduce contractor tax when paying interest to foreign contractors. Specifically:<\/span><\/p>\n

Double Taxation Agreement (DTA)<\/b><\/h2>\n

Interest from certain foreign governments may be exempt from withholding tax if a Double Taxation Agreement (DTA) applies or based on a separate agreement between the governments. For example:<\/span><\/p>\n