Tiếng Việt
中文A public non-business unit that partially self-finances its regular expenditures must pay corporate income tax on income from the production and business of goods and services, except for tax-exempt income as prescribed by tax law.
1. What is a partially self-financing public non-business unit?
Under Decree No. 60/2021/ND-CP regulating the financial autonomy mechanism of public non-business units, a partially self-financing public non-business unit is a unit whose non-business revenue covers part of its regular expenditures, with the remainder funded by the State budget.
2. Corporate income tax obligations of public non-business units
Under the Law on Corporate Income Tax No. 67/2025/QH15 and Decree No. 320/2025/ND-CP, a public non-business unit engaged in the production and business of goods and services with taxable income is a corporate income tax payer.
Specifically:
- Income from the production, business, and service activities of the non-business unit must be declared and corporate income tax paid thereon as prescribed;
- State budget funding granted for political and non-business tasks is not taxable income for corporate income tax purposes;
- The unit may deduct deductible expenses when determining taxable income if the conditions on invoices, documents, and payment are met as prescribed.
3. Declaring and paying corporate income tax
A public non-business unit shall conduct tax registration, declaration, and payment of corporate income tax in accordance with the Law on Tax Administration No. 108/2025/QH15 (effective from 01/7/2026, replacing the 2019 Law on Tax Administration). The unit needs to separately account for taxable income from production and business activities and revenues and expenditures from State budget sources.
Notes on application
Earlier tax guidance for public non-business units (such as Circular No. 150/2010/TT-BTC) should be cross-checked against the current legal framework, particularly the 2025 Law on Corporate Income Tax and the financial autonomy mechanism under Decree No. 60/2021/ND-CP.
Common risks to note
- Failure to separately account for taxable business activities and State-budget-funded non-business activities;
- Omitting the corporate income tax declaration obligation for service revenues;
- Applying guidance documents that are no longer valid.
How can ANT Legal help?
ANT Legal supports reviewing the tax obligations of public non-business units, determining taxable income, and advising on compliance. For advice, please contact our lawyers at ANT Legal.
