Why crypto-asset tax is modeled after securities taxation

The Ministry of Finance has issued a circular guiding taxation for crypto-asset transactions, setting a personal income tax rate of 0.1% of the transfer price per transaction for individual investors who trade through service providers. The circular applies to all individual investors regardless of residency status and uses a securities-like approach.

Tax framework: 0.1% on transfer value per transaction

Under the circular, individual investors are subject to personal income tax when transferring crypto assets via service providers. The tax rate is 0.1% of the transfer price for each transaction, and the method is described as equivalent to the taxation approach applied to securities.

Rationale for taxing transfer value

Lawyer Dao Tien Phong, Director of Investpush Law Firm, said the transfer-value basis is a simple and quick calculation method. He views the policy as cautious for the initial phase, focusing on establishing tax collection and cash-flow monitoring before moving toward a capital gains-based model that would require more extensive data, accounting standards, and reconciliation mechanisms.

He cited three main reasons for using transfer value:

• Operational precedent: A similar mechanism has been used in practice for years, with tax deducted directly on the transfer value through securities firms, helping control cash flow and reduce leakage.
• Comparable trading characteristics: Crypto assets are traded continuously with price fluctuations and high volumes in short periods, similar to securities. Taxing based on transfer value avoids complex issues around cost basis, trading history, and asset transfers across wallets and platforms.
• Consistency during early implementation: A securities-like model can be implemented and tested more quickly when there is limited time to fully develop a more complex framework, supporting early compliance.

Industry view: simplicity, but need clarity on the taxable event

A head of an affiliate marketing business for major exchanges in Ho Chi Minh City said that adopting a securities-like tax can be easier for both regulators and investors to understand and apply. The approach allows transaction values to be recorded and tax to be deducted immediately at the service provider, similar to how securities companies deduct tax when investors sell shares.

However, he cautioned that the taxable event must be clearly defined—whether it is triggered per transaction converted to money or per order on the exchange. Unlike securities, crypto trading can involve coin-to-coin swaps (such as Bitcoin to Ether), selling into stablecoins, or transferring assets to internal or cold wallets.

“If the taxable event is not clarified, investors may face the risk of double taxation.”

Concerns raised by Binance

In comments submitted to the Ministry of Finance in September 2025, Binance argued that taxing total transaction value—even at a low rate—could reduce trading motivation. Binance said the tax would apply to every trade, including cases where the seller incurs losses, and that high-frequency trading strategies could become infeasible due to the large number of low-margin trades executed by algorithms.

Binance contended that applying the tax uniformly across such activities could result in tax obligations exceeding actual profits, potentially dampening trading and market liquidity. It noted that similar negative effects have been observed in jurisdictions using comparable tax regimes.

Example: Indonesia’s experience

Binance cited Indonesia’s policy as an example: Indonesia imposes a 0.22% tax on crypto-asset transfers. It reported that in 2023, crypto-asset tax revenue fell by 63% after the tax method was introduced in May 2022, despite a rise in Bitcoin prices.

Potential impact on investors and possible future shift

Lawyer Dao Tien Phong said that for short-term investors, a 0.1% tax can significantly erode profits. He emphasized that the issue is not only the rate, but also the mechanism of taxing based on transaction value rather than realized profits. While the approach supports immediate tax collection and easier monitoring, it may not accurately reflect an investor’s true income.

“In markets with high trading frequency like digital assets, this becomes more sensitive than in traditional markets,” he observed.

Looking ahead, experts suggested that as Vietnam’s crypto market develops and the management system can track cost, expenses, and trading history, Vietnam could gradually transition to a tax model based on realized profits. They said this approach is used by many large markets to improve fairness and competitiveness.