UPDATED REGULATION ON MEAL ALLOWANCES IN 2025

Current regulation on meal allowances

The maximum amount of meal allowance exempt from personal income tax is 730,000 VND/person/month, as stated in Clause 4, Article 22 of Circular 26/2016/TT-BLĐTBXH (now expired).

According to Point g.5, Clause 2, Article 2 of Circular 111/2013/TT-BTC:

• If the enterprise organizes meals directly (e.g., cooking, buying meal portions, issuing meal vouchers): the amount is not subject to personal income tax.
• If the enterprise pays cash for meals to employees: the amount is exempt from personal income tax only if it does not exceed the level guided by the Ministry of Labor, Invalids and Social Affairs; any excess must be included in taxable income.

Key updates under Circular 003/2025/TT-BNV and Decree 44/2025/NĐ-CP

Starting from June 15, 2025, Circular 26/2016/TT-BLĐTBXH is officially repealed and replaced by Circular 003/2025/TT-BNV. At the same time, the Government issued Decree 44/2025/NĐ-CP, effective from April 15, 2025, providing more detailed regulations on mid-shift meal allowances for employees.

Notable changes:

• The cap of 730,000 VND/person/month for personal income tax exemption under Circular 26/2016/TT-BLĐTBXH has been officially abolished (based on Point b, Clause 2, Article 19 of Circular 003/2025/TT-BNV).
• From 2025 onward, mid-shift meal payments will be based on agreements between employers and employees, specifically stated in Collective labor agreements, or Company regulations and policies, in accordance with Clause 9, Article 34 of Decree 44/2025/NĐ-CP, and aligned with the Labor Code.