Are wages for unused annual leave subject to Personal Income Tax (PIT)?

Question: In the case where the company pays for unused annual leave days, is this amount subject to personal income tax (PIT)?

At Point a, Clause 1, Article 2 of Circular 111/2013/TT-BTC stipulates taxable personal income (TNCN), including income from salaries and wages received by employees from employers, as follows:

a) Salaries, wages and amounts of a salary or wage nature in forms of money or non-monetary items.

And at Clause 3, Article 113 of the Labor Code 2019 stipulates:

In cases of resignation or job loss without having yet taken annual leave or not taking the full number of annual leave days, the employer is required to pay wages for the untaken leave days.

=> Hence, currently if an employee terminates the labor contract without having taken the full number of annual leave days within the year, they will be compensated for the untaken annual leave days. Essentially, this is also considered as salaries and wages for the employee. Therefore, in my opinion, this amount should be subject to TNCN tax. Respectfully.

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