Before addressing each question, you need to understand a core point: Circular 32/2026/TT- BTC is not written in a way that says "everyone trading crypto can apply it immediately," but rather it is based on a pilot framework, so its scope of application is limited by the type of transaction and the method of trading. Therefore, if you only skim through it, it's easy to misunderstand that it applies to all exchanges, that all transactions are taxed the same, or that every trade is subject to a 0.1% deduction. In reality, it's not that simple.
The following section will answer the three most common questions: which exchanges are actually subject to the regulations, who is responsible for paying the taxes, and how to understand the effective date. Let's start with the most important question: are current DEX/CEX exchanges within the scope of these regulations?
1/ Are these regulations applicable to current DEX/CEX platforms?
Answer: This Circular does not automatically apply to all DEX and CEX platforms globally. According to Article 1, this Circular provides tax guidance based on a pilot framework: "This Circular provides guidance on value-added tax, corporate income tax, and personal income tax, and the timing of revenue and income determination for transactions, transfers, and trading of crypto assets in accordance with Resolution No. 05/2025/NQ-CP dated September 9, 2025, of the Government on the pilot implementation of the crypto asset market in Vietnam." This means it only applies to and is directly binding on domestic CEX platforms (organizations providing crypto asset services) licensed to participate in the pilot program. Decentralized DEX platforms and international CEX platforms like BingX are not under the direct management of this framework as they do not have legal entities in Vietnam.
2/ Is the 0.1% tax applied to domestic exchanges or is it self-declared (cash out) by individuals?
Answer: Domestic exchanges (part of the pilot program) will be the ones withholding tax. Specifically, Article 5 stipulates: "Investors who are individuals (regardless of whether they are resident or non-resident) engaging in the transfer of crypto assets through crypto asset service providers are subject to personal income tax at a rate of 0.1% on the transfer price for each transaction." According to this regulation, the 0.1% tax is calculated "through the service provider," meaning domestic exchanges will collect and pay it on behalf of the tax authorities (similar to securities companies). For transactions taking place on international exchanges (such as BingX) or through P2P exchanges, individuals negotiate the tax themselves, and since the exchange is not part of the pilot program, it has no obligation to collect the tax. From July 1st, 2026, according to general tax law principles, individuals with income will have to self-declare when transferring cryptocurrency assets. However, if the individual's cryptocurrency asset transfer activity is of a business nature, it may be subject to tax under the business tax category as determined by the tax authorities at any given time.
3/ The document doesn't specify that it applies to domestic Vietnamese exchanges, only stating that it starts from March 27th?
Answer: The Circular stipulates that the scope of application is defined through specialized terminology in Clause 2, Article 4: "Enterprises that are organizations providing crypto asset services as stipulated in Clause 3, Article 3 of Resolution No. 05/2025/NQ-CP and have income from providing crypto asset services are subject to corporate income tax at a rate of 20%...". At the same time, Clause 1, Article 7 also states: "This Circular takes effect from March 27, 2026 and is implemented according to the pilot implementation period stipulated in Clauses 2 and 3, Article 18 of Resolution No. 05/2025/NQ-CP...". This automatically limits the scope of application to Vietnamese enterprises operating within the framework of Resolution No. 05/2025/NQ-CP. However, the effective dates of regulations related to personal income tax and corporate income tax must comply with the regulations of each specific regulation (for example, the collection of tax on the transfer of digital assets as stipulated in Point d, Clause 10, Article 3 of the Personal Income Tax Law 2025 will take effect from July 1, 2026).
