Short answer: It depends. Where the owner of a single-member LLC owned by an individual also directly manages the company: the owner’s salary is not deductible for corporate income tax (CIT) purposes, so the social and health insurance contributions calculated on that salary are also not deductible. Conversely, where the company hires a director/other employees (not the owner): the social and health insurance costs the enterprise pays for them are deductible if fully documented and within prescribed limits.
Legal basis
- Article 6 of Circular 78/2014/TT-BTC, as amended by Circular 96/2015/TT-BTC;
- The Law on Social Insurance 2024 (No. 41/2024/QH15, effective from 01/07/2025);
- Note: at the time of finalisation, the Law on CIT 2025 (No. 67/2025/QH15) also applies.
Case 1: The owner also manages the company
- Salaries and remuneration of the owner of a single-member LLC owned by an individual are not deductible for CIT;
- Accordingly, the social, health and unemployment insurance contributions calculated on such salary are also not deductible;
- This is the consistent position of tax authorities in many guidance letters.
Case 2: Hiring others to manage
- Salaries of hired directors/employees are deductible if general conditions are met (actually paid, documented, stated in the contract/internal regulations);
- The social, health and unemployment insurance and trade union fees contributed by the enterprise at prescribed levels are deductible;
- The portion contributed in excess of prescribed levels is not deductible.
The company owner’s social insurance obligations under the 2024 Law
- The 2024 Law on Social Insurance expands compulsory social insurance participants to include enterprise managers;
- Company owners should determine whether they are compulsory or voluntary participants to join correctly;
- Regardless of insurance participation, the CIT deductibility rules apply as analysed above.
If you need to determine the appropriate approach for your specific situation, you should discuss it with a lawyer beforehand to have your file reviewed and a suitable solution advised.
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