This article aim to comprehensively analyze the nature of the "ERC first - IRC later" mechanism under the lens of the Law on Investment 2025 and its guiding documents. Accordingly the article assesses the two-way impacts on foreign investors, identifies bottlenecks and potential legal conflict gaps, and provides strategic recommendations.

In the context of a robust economic recovery, the Government and the National Assembly have issued significant financial “leverage” policies to support the private sector. Notably, the policy of Corporate Income Tax (CIT) exemption for the first 03 years for newly established small and medium-sized enterprises (SMEs) is being hailed as a vital “breath of oxygen” to help startups optimize cash flow during their challenging initial stages.

The Amending Law amends and supplements many issues, such as the Organizational Model of the People's Courts; Duties and Jurisdictions of the People's Courts; and the Jurisdiction of the People's Courts in relevant laws. This amendment and supplementation is a consequence of the comprehensive reform currently underway in Vietnam's administrative structure, transitioning from a three-level to a two-level local governance model.