IT ' S SMART

The guide performs the applicable tax obligation to the organization, individual

foreign business in Vietnam or has a birth income in Vietnam.

______________________

Increased Value Tax Law Base 13 /2008/QH12 03 June 2008; Law amended, supplematuation of a number of GTGT Tax Law 31 /2013/QH13 June 19, 2013; Decree No. 209 /2013/NĐ-CP December 18, 2013 of the Government rules the details and guidelines that implement some of the valuing Tax Law;

Corporate Income Tax Law Base 14 /2008/QH12 03 June 2008; Law amended, supplematuation of a number of TNDN Tax Law 32 /2013/QH13 June 19, 2013; Decree No. 218 /2013/NĐ-CP December 26, 2013 of the Government rules the details and guidelines for the implementation of the Enterprise Income Tax Act;

Tax Management Base 78 /2006/QH11 November 29, 2006; Amendment law, which complements some of the provisions of the Digital Tax Management Law 21 /2012/QH13 November 20, 2012;

Base of Protocol 215 /2013/ND-CP December 23, 2013 of the Government rules on the functions, duties, powers, and organizational structure of the Ministry of Finance;

On the recommendation of the Attorney General of the General Directorate of Taxation;

The Minister of Finance issued a guide to the implementation of the applicable tax obligation to the organization, the foreign individual business in Vietnam or having the income in Vietnam as follows:

Chapter I

GENERAL REGULATION

Number one. Apply objects

The guide at this message applies to the following subjects (except for the case set at Article 2 Chapter I):

1. The foreign foreign organization has a permanent basis in Vietnam or has no permanent basis in Vietnam; foreign-business individuals are subject to residence in Vietnam or not a resident subject in Vietnam (later known as the Water Contender). In addition, the foreign subcontractor) business in Vietnam or has a birth income in Vietnam on a contract basis, agreement, or a commitment between foreign contractors with the organization, the Vietnamese individual or the middle of the foreign contractor with the Foreign Contractors Contractor. to do part of the work of the contractor contract.

2. Organization, foreign individuals provide goods in Vietnam in the form of an export-based import and has an income birth in Vietnam on the basis of a contract signed between the organization, foreign individuals with businesses in Vietnam (except for public contracting). and export goods to the organization, foreign individuals) or perform a distribution of goods in Vietnam or provide goods under the delivery conditions of the international trade terms-the Incentive that the seller is at risk related to the goods at the time. Vietnam.

Example:

-Case 1: Business X in foreign countries sign a contract to purchase the fabric of Vietnam Business A, while only planning a delivery of A delivery for Vietnamese business South B (in the form of export-based import). The X-based business was born in Vietnam on the basis of a contract signed between the X business with business B (the X sales of the fabric to the B business).

In this case, the X business is subject to regulatory application at this Smart, and business B is responsible for opening, deductible and paying taxes in place of X business in accordance with this.

-Case 2: The foreign Y business contracted cloth co-workers with Vietnamese business C, while also designated a C-delivery business for Vietnamese businesses to continue manufacturing (in the form of export-based import) at the time. the law). Business Y has an income in Vietnam on the basis of co-contracting between the Y business with Enterprise D (Business Y sales for Business D).

In this case, the Y business is subject to regulatory application at this Smart and Business D is responsible for opening up, deductible and paying taxes instead of the prescribed Y business at this Smart.

-Case 3: Business Z in foreign countries signs a contract or purchase of cloth with Vietnam Business E (Business Z provides raw materials for E business to be machinable) and designated a delivery E business for Vietnam business to continue. It is, in the form of a public entry (in the form of a law of entry). After the family is finished, the G-Business returns to Business Z and Business Z must pay the public money for the G business under a macho contract.

In this case, the Z business is not subject to the prescribed application at this level.

3. Organization, foreign individual who does part or the entire business distribution of goods distribution, providing services in Vietnam in which the organization, foreign individual remains the owner of the goods assigned to the Vietnamese organization or is responsible for the operation of the organization. of the cost of distribution, advertising, marketing, quality of service, the quality of goods delivered to the Vietnam organization or the valuation of the sale of goods or prices of services; including the case of proxy or hiring some Vietnamese organizations performing part of the service. Distribution, other service related to the sale of goods in Vietnam.

Example 2:

Business A in the country in addition to delivery of goods or authorization to carry out some related services (such as shipping, distribution, marketing, advertising ...) to Vietnam Business B in which Business A is the owner for the goods assigned to Business B or Company. Business A is responsible for the cost, quality of service, the quality of goods delivered to Enterprise B or Enterprise A price of a sales price or service supply price, Business A is subject to regulation at this Smart.

4. The organization, the foreign individual through the organization, the Vietnamese individual to carry out the negotiation, sign up to the organization of the organization, the foreign individual.

5. Organization, foreign individuals exercise the right to export, the right to import, distribute in the Vietnamese market, buy goods for export, sell goods to Vietnamese traders under the law of trade.

Article 2. The object does not apply

The instructions at this message do not apply to:

1. Organization, foreign individual business in Vietnam by the provisions of the Investment Law, Petroleum Law, Law of Credit Organizations.

2. Organization, foreign individuals who carry out the supply of goods to the organization, Vietnamese individuals are not accompanied by services made in Vietnam under the forms:

-Delivery at a foreign outlet: the seller is responsible for all responsibility, costs, risks associated with the export of goods and delivery at the foreign outlet; the buyer is responsible for all responsibility, costs, risks associated with the receiving, the delivery charge from the store. Foreign to Vietnam (even the case of a foreign shop with a warranty clause is the responsibility and duty of the seller).

-Delivery at the Vietnam store: the seller is responsible for all responsibility, costs, risks associated with goods to the delivery point at the Vietnam store; the buyer is responsible for all responsibility, costs, risks associated with the receiving, the cargo from the store. Vietnam (even the case of delivery at the Vietnamese store with the warranty clause is the responsibility and duty of the seller).

Example 3:

The company C in Vietnam signed a contract to import cargo shipments, bulldozers with Company D overseas, and deliveries were made at the Vietnamese store. Company D is responsible, the cost associated with the shipment to the delivery point at the Vietnam store; Company C is responsible for, the cost involved in the delivery, the shipment of goods from the Vietnamese store. The contract had a shipment agreement on the Company D for 1 year, in addition to Company D not performing any other service in Vietnam in relation to the above shipment. In this case, the operation provides the goods of the Company D of the non-applicable object of the Wise.

3. Organization, foreign individuals with income from the service offered and consumer outside of Vietnam.

Example:

Hongkong's H Company provides cargo and cargo services at Hong Kong's Hong Kong port for the International Transport Flotilla of Vietnam. Company A must pay the Company to waste its cargo at the Port of Hongkong.

In this case, the inventory of goods at Hongkong Port is that the service offered and consumed at Hongkong should not be subject to a tax subject in Vietnam.

For example, 5:

The foreign organization provides specialized services, management, and issuing bonds, legal advice, management agents, roadshow organization (a brand activation array operation) for the Company A in Vietnam in countries where the Company A release certificates for the Vietnam War. The GDR (Global Depositary Receipt) and international bonds do not belong to the applicable foreign organization.

4. The organization, the foreign individual who does provide the following service offering to the organization, the Vietnamese individual that services are made abroad:

-Repair of transport (flying boats, flying boat engines, flying parts, sea ships), machinery, equipment (including sea cable, transmission equipment), which include or does not include supplies, equipment replaced with;

-Advertising, marketing (excluding advertising, internet marketing);

For example, 6:

Vietnam's business contracted with the organization in Singapore to carry out a product advertising service in the Singapore market, and Singapore's advertising service was not subject to the application's application. In Singapore, the company in Singapore has made a product advertisement for consumption in the Vietnamese market, and the income from this advertising service is subject to the applicable subject.

-Promotion of investment and commerce;

-The brokerage: sales of goods, provide services abroad;

Example:

Vietnam 's business contracted business lease in Thailand to carry out a brokerage service to sell the products of Vietnam' s business in the Thai market or the world market then the Thai business ' s brokerage service is not subject to the subject. the application of the Wise; the case of the Vietnamese business contracted the business lease in Thailand to deliver a brokerage service to the Vietnamese business in Vietnam, which is subject to the application of the applicable information.

-Training (except online training);

Example 8:

Company A in Vietnam signed with Singapore 's School B to staff Vietnam to Singapore to study at Singapore' s University B the training service of the University B School is not subject to the applicable subject of the Information; the case of Company A in Singapore. Vietnam signed a contract with the University of Singapore to teach Vietnamese staff to Vietnam in the form of online learning, the online training service of the University of B under the applicable subject matter.

-Shares of service (payment) services, international telecommunication between Vietnam with foreign countries where these services are carried out outside Vietnam, the country ' s network of transmission and satellite leasing services under the regulation of the Telecommunications Law; Separation (ID). payment) international postal service between Vietnam and Vietnam under the provisions of the Postal Law, the international treaties of the Post that the Socialist Republic of Vietnam participated in the signing that these services were carried out outside Vietnam.

5. Organization, foreign individuals use external warehouses, domestic ports (ICD) as a warehouse to support international transport operations, transit, shipping, storage, or for other businesses to join.

Third. Explain the word

In this Information, the words below are understood as follows:

1. "Contract contracts" are contracts, agreements or commitments between foreign contractors and the Vietnamese side.

2. The "subcontractor contract" is the contract, agreement or commitment between the subcontractor and the foreign contractor.

The subcontractor consists of the Foreign Minister and the Vietnamese subcontractor.

3. Vietnam Territory includes land territory, islands, internal, territorial, and the sky above it, the waters off the territorial waters, including the seabed and the ground at the bottom of the sea where Vietnam performs sovereignty, the sovereignty rights and the right jurisdiction. with Vietnamese law and international law.

Article 4. Taxpayers

1. Foreign contractor, Foreign subcontractor ensuring the conditions stipulate in Article 8 Section 2 Chapter II or Article 14 4 Chapter II, business in Vietnam or having income in Vietnam. The business is conducted on the basis of a contractor contract with the organization, the Vietnamese personally or with the organization, other foreign individuals who are operating business in Vietnam on the basis of a subcontractor contract.

The identification of foreign contractors, foreign contractors with a permanent basis in Vietnam, or the subject of residence in Vietnam by the provisions of the Tax Income Tax Act, the Personal Income Tax Act, and the implementation of the execs.

In the case of the two-time tax avoidance Agreement that the Socialist Republic of Vietnam has other regulation on a permanent basis, the subject of residence is done by the stipulation of that Agreement.

2. The organization is established and operates under the Vietnamese law, which organizes the registration of activities under Vietnamese law, other organizations and individuals who produce business: purchase services, services tied to goods or to pay income in Vietnam on a legal basis. co-contractors or subcontractor contracts; purchase of goods in the form of export export in place or under international trade terms (Incoterms); implement the distribution of goods, provide services in place of the organization, foreign individuals in Vietnam (the following) It ' s called " " Vietnam. " "

-Business organizations are established under the Corporate Law, Investment Law and Cooperated Law;

-Economic organizations of political organizations, political-social organizations, social organizations, social organizations-professions, armed units, career organizations and other organizations;

-Oil contractors operating under the Oil and Gas Act;

-Branch of the Foreign Company is allowed to operate in Vietnam;

-The foreign organization or representative of the foreign organization is allowed to operate in Vietnam;

-Ticket sales office, Vietnam ' s rep in Vietnam of the foreign airline has the right to transport, to Vietnam, directly shipping or in contact;

-Organization, personal business business personality of the offshore shipping company; agents in Vietnam of the depot.

-Stock company, equity organization, fund management company, commercial bank where securities investment fund or foreign organization open securities investment accounts;

-Other organizations in Vietnam;

-Business-producing individuals in Vietnam.

The taxpayer in accordance with the guidelines at paragraph 2 Article 4 I have the responsibility to deduct the number of valuing tax, the tax income tax is directed at Section 3 Chapter II before payment to the Foreign contractor, the Foreign Contractor.

Article 5. The taxes apply

1. Foreign contractor, foreign subcontractor is the business organization that performs an increased value tax obligation (GTGT), corporate income tax (TNDN) in the direction of this Information.

2. Foreign contractor, Foreign Contractor is a business foreign individual who performs a GTGT tax obligation in the guidance of this Information, the personal income tax (TNCN) under the TNCN tax law.

3. For taxes, fees and other charges, Foreign contractors, Foreign Contractors to implement legislation on taxes, fees, and other fees available.

Chapter II

BASE AND TAX.

Item 1

GTGT TAXABLE SUBJECT AND TNDN TAXABLE INCOME

Number 6. GTGT tax subject

1. Service or service attached to the goods belonging to the GTGT tax subject to the Foreign contractor, the foreign subcontractor provided on the basis of the contractor contract, the contractor contract which uses for manufacturing, business and consumption in Vietnam (except for the school). The provisions of Article 2 of Chapter I, including:

-Service or service attached to the goods belonging to the GTGT tax subject issued by Foreign contractor, Foreign Contractor provided in Vietnam and consumption in Vietnam;

-Service or service attached to the goods belonging to the GTGT tax subject due to foreign contractors, foreign contractors supplying Vietnam and consumption in Vietnam.

2. The case of goods is provided under contract in the form: the point of exchange of goods located within the territory of Vietnam (except for the specified case at 5 Article 2 Chapter I); or the provision of goods accompanied by the service conducted in Vietnam as installation. sets, test, warranty, maintenance, alternative, other services that come with the provision of goods (including the case of a free service), including the case of providing the above-listed services or not in the value of the supply contract. merchandise then the commodity value is only subject to the prescribed GTGT tax, the portion of the service value subject to the GTGT tax subject in the direction. This is the announcement. The contract case does not separate the value of the goods and the associated service value (including the case of a free service), the GTGT tax is generally given to the contract.

Example:

Business A in Vietnam signed a contract to purchase machinery for the cement plant project with Business B overseas. The total contract value was $100 million, including $80 million (including a GTGT taxable equipment with a 10% tax), the installation of installation guidance, installation surveillance, maintenance, and maintenance of $20 million.

The identification of Company B ' s GTGT tax obligation on the value of co-signing with business A as follows:

-The GTGT tax is calculated on the service value ($20 million), not counting on the value of the imported device machinery.

-The contract case does not separate the value of the device's machinery and service value, the GTGT tax is calculated on the entire contract value ($100 million).

Article 7. TNDN tax income

1. Foreign contractor TNDN of Foreign contractor, Foreign Contractor is the income that arise from supply operations, distribution of goods; provision of services, services tied to goods in Vietnam on the basis of the contractor contract, the subcontractor contract (excluding). case of regulation at Article 2 of Chapter I).

2. The case of goods is provided in the form: the point of trading of goods located within the territory of Vietnam (excluding the specified case at paragraph 5 Article 2 Chapter I); or the provision of goods included with some services conducted in Vietnam such as service. marketing advertising (marketing), commercial promotion activities, post-sales services, installation services, testing, warranty, maintenance, replacement, and other services that come with the provision of goods (including cases of free services), including: case of the provision of the above or not located in the value of the contract offering goods then the TNDN taxable income of the contractor. Overseas, foreign subcontractor is the full value of goods, services.

Example 10:

Company A in Vietnam signed a contract to purchase machinery for the cement plant project with Company B overseas. The total contract value was $100 million (not including the GTGT tax), including $80 million in equipment, installation, installation, maintenance, maintenance, $20 million.

The Company B ' s TNDN tax obligation for the contract value is determined as follows:

-The TNDN tax is calculated separately for the value of the imported equipment chain ($80 million) and is calculated for the value of the service ($20 million) according to each of the prescribed TNDN tax rates.

-The case of a non-determinable contract value of the device's machinery and service value is the TNDN tax on the total contract value ($100 million) with a prescribed TNDN tax rate.

3. Income in Vietnam of the Foreign contractor, the Foreign Contractor is the income received under any form on the basis of the contractor contract, the subcontractor contract (except for the specified case at Article 2 Chapter I), no extra charge. to the site of the business activities of the Foreign contractor, the foreign contractor. The taxable income of the Foreign contractor, the Foreign Contractor in some particular cases is as follows:

-Income from ownership of ownership, property rights; transfer of the right to economic contract/project in Vietnam, transfer of property rights in Vietnam.

-Income from royalties is the income under any form paid for the right to use, transfer of intellectual property rights and transfer of technology, software copyright (including: funds paid to the right to use, transfer of the author ' s rights and rights). the ownership of the work; the transfer of industrial ownership; technology transfer, software copyright).

"Copyright rights, rights to the owner of the work", "Industrial Property Rights", "technology transfer" regulations at the Ministry of Civil Law, Intellecintellectual Property Law, technology transfer law, and execs of instructions.

-Income from transfer, asset liquation.

-Income from the loan interest: is the lender 's income from loans under any form that the loan has or is not guaranteed by the mortgage, that the lender does or does not enjoy the borrower' s return; income from deposit rate (excluding). The deposit of foreign individuals and interest deposits was issued from the deposit account to maintain operations in Vietnam by the diplomatic representative body, the representative body of the international organization, the non-governmental organization in Vietnam. add to the deposit expense (if available); income from interest is slow by the regulation of contracts; income from bond interest, bond price discount (minus the left). Tax-free, treasury vote; income from the deposit.

The loan interest includes both the fees that the Vietnamese side must pay under the contract of the contract.

-Income from the stock exchange.

-The fine, the compensation proceeds from the breach of the contract.

-Other income according to the law.

Item 2

THE GTGT TAX IN ACCORDANCE WITH THE DEDUCTION, FILE TAX TDN ON A REVENUE MANIFEST BASIS, COSTS TO DETERMINE TAXABLE INCOME. (the following is called the manifest method)

Article 8. Applicable objects and conditions

Foreign contractor, Foreign Contractor pays tax in accordance with the guidelines at Section 2 Chapter II if the following conditions are met:

1. There is a permanent basis in Vietnam, or the subject of residence in Vietnam;

2. The business deadline in Vietnam under the contract of the contractor, the contract for the subcontractor from 183 days or more since the date of the contractor contract, the contractor contract is in effect;

3. Apply the Vietnam Accounting Mode and perform tax registration, which is tax-coded by the tax code.

Article 9. Value Value Tax

Follow the rules of the GTGT Tax Law and the execs of the execs.

Article 10. Corporate income tax

Follow the regulation of the TNDN Tax Law and the execs of the execs.

Section 3

GTGT TAXPAYER, TNDN TAX IN ACCORDANCE WITH THE RATE OF CHARGE ON REVENUE (the following is called the direct method)

Article 11. Applicable objects and conditions

Foreign contractors, Foreign Contractors do not meet one of the conditions listed at Article 8 2 Chapter II, Vietnam paid tax changes to foreign contractors, foreign contractors in accordance with Article 12, Article 13 Section 3 Chapter II.

Article 12. Value Value Tax

The tax base is an increase in value tax revenue and percentage to calculate the GTGT tax on the revenue.

The number of GTGT taxes must be filed

=

Value Value Tax Revenue

x

Percentage to calculate GTGT tax on revenue

Foreign contractors, Foreign Contractors Belonging To The GTGT tax subject directly based on GGTGT are not deductible of the GTGT tax on goods, services purchased in order to implement the contractor contract, the subcontractor contract.

1. GTGT Tax Revenue

a) GTGT tax revenues:

The GTGT tax revenue is the full revenue provided by the service, services tied to the GTGT taxable subject goods that the foreign contractor, the foreign contractor received, excluding the taxes required to submit, including the expenses paid by the Vietnamese side. South to replace the foreign contractor, the foreign subcontractor (if any).

b) Define the GTGT tax collection for certain specific cases:

b.1) The case under the agreement at the contractor contract, the subcontractor contract, foreign contractor revenue, the foreign contractor received not including the GGTGT tax must submit, the GTGT tax revenue must be converted to a GTGT tax and tax revenue. is determined by the following formula:

GTGT Tax Revenue	=	The revenue has not included the GTGT tax
		1-Rate of% to calculate GTGT tax on revenue

Example 11:

The foreign contractor A provides the Viet Cong to oversee mass surveillance of the Z cement plant, the contract price that has not included the GTGT tax (but has included the TNDN tax) of $300,000. In addition, the Vietnamese side arranged the accommodation and worked for the management staff of the Foreign contractor A with the value that had not included the GTGT tax of $40,000. According to the contract, the Vietnamese side is responsible for paying the GTGT tax in place of the foreign contractor. The identification of the GTGT tax revenues of the foreign contractor A as follows:

Specifies tax revenue:

GTGT Tax Revenue	=	300,000 + 40,000	=	$357,894.73.
		(1-5%)

b.2) The case of foreign contractor signing contracts with the Vietnam subcontractor or foreign subcontractor does pay tax in accordance with a prescrip method or a Foreign Contractor in accordance with the mixed method of dealing with a portion of the work value or The category for subcontractors is regulated at the Contract of Contender with Vietnam and the list of Vietnamese subcontractors, foreign contractors who do part of the work or the respective categories listed included in the Contract of Contractors. The GTGT tax of the Foreign contractor does not include the work value issued by the Vietnam Contractor Or foreign subcontractor.

The case of foreign contractors contracted to provide suppliers in Vietnam to purchase raw materials, machinery to implement contractor and cargo contracts, services to serve internally, consumer non-item, The work that the foreign contractor does on a contractor contract is worth a commodity, and this service is not unless it is determined to determine the tax revenues GTGT of the foreign contractor.

Example 12:

Foreign contractor A signed a contract to build Z cement plant with Vietnam for a total contract value of $10 million (the price that included the GTGT tax). According to the contractor Contract, the Foreign contractor A will hand over the portion of the construction value (stipulated at the contractor contract with Vietnam) to the Vietnamese subcontractor B with a value of $01 million (the price has not included the GTGT tax); in addition, during construction. set up the Z cement plant to implement the contractor contract, the foreign contractor A purchase of raw materials (bricks, cement, sand etc.) to implement construction and purchase of goods, services such as car rentals, hotels for professionals, purchasing stationery ... catering to the Make a deal.

The GTGT tax revenue of the foreign contractor A in this case is determined as follows:

GTGT tax revenue = $10 million-$1 million = $9 million

The GGTGT tax revenues of the A foreign contractor A are not excluded from the raw materials, goods, services such as car rental, hotel rental for professionals, purchasing stationery offices ...

b.3) The case of foreign contractor contracting with Foreign Contractor Practices in accordance with the direct method of paying taxes on a direct method, Vietnam pays the GTGT tax in place of foreign contractor, the foreign contractor in proportion to the percentage to calculate GTGT on business. proceeds to the business sector that the foreign contractor, the foreign contractor that exercises the contract, the subcontractor contract. Foreign subcontractors do not submit a GTGT tax on the portion of the work value of the Foreign Contractor Implementation in accordance with the provisions at the Contract of the Contracting Contractor with Foreign Contractor that Vietnam has filed instead.

b.4) The GTGT tax revenue for machine leasing, equipment, transport is the full amount of rent. The case of machine rental revenue, equipment, transportation including expenses paid by the side directly paid such as media insurance, maintenance, registration certification, vehicle control, machinery and transportation costs. From overseas to Vietnam, GTGT tax revenue does not include these costs if there is evidence from reality.

b.5) For the delivery service, the international depot from Vietnam to foreign countries (not to distinguish the senor or the paid recipient), the GTGT tax revenue is the entire foreign contractor revenue received not including the required international shipping. Pay the carrier (aviation, sea).

b.6) For an international transfer service from Vietnam to foreign countries (not to distinguish it from deposers or payers), GTGT tax revenues are all foreign contractor revenues received.

Example 13:

The overseas company provides mail delivery services from abroad to Vietnam and vice versa. The Company A ' s GTGT tax revenues are defined as follows:

+ For the overseas transfer service of Vietnam (which does not distinguish persons from overseas or recipient in Vietnam paid for service) is not subject to a GTGT tax;

+ For services from Vietnam to foreign countries (not to distinguish persons in Vietnam or foreign recipient), the tax revenue of GTGT is the entire Company A received.

Example 14:

Company B (Vietnam Company) provides mail delivery services from abroad to Vietnam and vice versa. To carry out this service, Company B payment (split) to the Company C in the country in addition to a sum of x USD. The Company ' s GTGT tax is defined as follows:

+ For overseas transfer services to Vietnam (not to distinguish persons from overseas or recipient in Vietnam to pay for service), the $x Company of the Company C received is not part of the GTGT tax revenue;

+ For the service of transfers from Vietnam to foreign countries (not to distinguish persons in Vietnam or foreign recipient), the $x Company C received from the GTGT tax revenue; Company B is responsible for opening, deductible, submit to the GTGT tax on the amount x payment for Company C.

2. Rate the percentage to calculate the GTGT tax on the revenue:

a) Rate the percentage to calculate the GTGT tax on revenue for the business sector:

STT	Business	Ratio for GTGT tax
1	The service, which lease equipment machinery, insurance; construction, installation of no materials, machinery, equipment, equipment and equipment.	5
2	Manufacturing, transport, service is attached to the goods; construction, installation of materials-including materials, machinery, equipment and equipment.	3
3	Other business activities	2

b) Define the ratio of% to calculate the GTGT tax on the revenue for certain specific cases:

b.1) For contractor contracts, the subcontractor contract includes a variety of business activities or a portion of the non-taxable contract value of the GTGT tax, which applies the percentage to the GTGT tax on the revenue when determining the required GTGT tax number. filed into the GTGT tax revenue for each business operation run by the Foreign contractor, the foreign subcontractor implemented by the stipulation at the contractor contract, the subcontractor contract. Where the value does not separate the value of business activity, it applies the percentage to the GTGT tax on the highest revenue for the business industry for the entire contract value.

For its construction activities, installation with materials or machinery, equipment accompanying construction work: The case of a separate contractor that is valued once a business operation, the foreign contractor does not have to pay the GTGT tax on its own. value of raw materials or machinery, equipment that has paid the GTGT tax in imported or non-taxing GGT; for each portion of the rest of the work on contract then apply the percentage to the GTGT tax on the revenue corresponding to the operation. Business. Where the contractor contract does not separate the value of a business operation, the ratio of% to calculating the GTGT tax on the revenue is 3% calculated on the entire contract value (including raw materials or machinery, imported equipment). The case of foreign contractor signing contracts with subcontractors to hand over the entire portion of the work value or category has a tenor of materials or machinery, equipment, foreign contractors only to implement the rest of the service value under contract. The bidder is the percentage to calculate the GTGT tax applied to the service industry (5%).

Example 15:

Foreign contractor A signed a contract with Vietnam to build an X power plant with a value of $75 million (the price that included the GTGT tax).

Case 1: Contract of a contractor separate the value of each business activity as follows:

+ The machine value, the supply device for the work: $50 million.

In it: The machine value, the GTGT taxable property: $30 million.

The value of the machinery, the non-taxable device of the GTGT tax: $15 million.

The warranty service value comes with machinery, equipment: $5 million.

+ Value of technology chain design, other design: $5 million.

+ Home value, other auxiliary system, construction, installation: $15 million.

+ monitoring service value, installation guide: $3 million.

+ Technical training service value, test operation: $2 million.

Upon imports, the value of the device machinery was paid $30 million in the import of GTGT; the value of machinery, the non-taxable equipment of the GGT $15 million.

The GTGT tax obligation of the Foreign contractor A for the value of the contract with the Vietnamese side is calculated only on the value of the service and the installation value. In it: service value (warranty services, design services, surveillance services, installation guidelines, technical training services, test operations) are $15 million and apply the percentage to the GTGT tax on the revenue to the service sector of 5%; construction value, The installation is $15 million and applies the percentage to the GTGT tax on revenue for construction activity, 3% (not counting GTGT tax on machine value, imported equipment).

Case 2: The contractor contract does not separate the value of each business, only regulation of contract value including machinery, equipment, design services, surveillance services, installation guidelines, technical training services, test operations; if there is not enough evidence to prove the value of the machinery, the equipment provided for the work that has paid the GGTGT tax in the import, the GTGT tax obligation of the Foreign contractor A for the value of the contract with the Vietnamese side is calculated on the entire value of the contractor contract of 75. million dollars and apply the ratio of% to calculate the GTGT tax of 3%.

Case 3: Foreign contractor A contracted with subcontractors to hand over parts of the work that includes materials, the foreign contractor A only does the portion of the service value (e.g., the value of the monitoring service, the installation direction) then the share price. This service applies the percentage to the GTGT tax on the revenue of 5%.

b.2) For the contract to provide a device machine with existing services in Vietnam, if a separate separation is a value of the device and the value of the services when determining the number of GGTGT taxes is applied, then apply the percentage to the GTGT tax on the revenue. of each part of the contract value. The case in the contract does not separate the value of the device's machinery and the value of the services, which applies the percentage to the GTGT tax on tax revenues of 3%.

Example 16:

The South Korean foreign contractor did not implement the Vietnam accounting regime that implemented a contract with business B in Vietnam about the supply of machinery, equipment and installation services, operating, and testing, with a value of $10,000,000. At the contract that does not separate the value of the equipment machinery and the installation service value, the running operation is the percentage to calculate the applicable GTGT tax rate of 3%.

3. The GTGT Tax against Foreign contractor, Foreign Contractor provides goods, services to conduct search operations, exploration, development and extraction of oil fields, gas and gas and gas.

a. The case of foreign contractors, Foreign Contractors offering goods, services to conduct search, exploration, development and extraction of oil fields, gas if not one of the conditions stated at Article 8 2 Chapter II, then Parties to the United States. Vietnam is responsible for deductible, paying for the GTGT tax before payment. The number of taxes filed on behalf of the total amount of payment has not included the GGTGT tax (x) with the specified GTGT tax rate for goods, services provided by foreign contractors.

b. The foreign contractor case, the foreign subcontractor that provides goods, services to conduct search activities, exploration, development and extraction of oil fields, gas meets three conditions stated at Article 8 Section 2 Chapter II or meet two conditions in the United States. set in paragraph 1, paragraph 2 Article 8 Section 2 Chapter II and organization of accounting accounting in accordance with the laws of accounting and guidelines of the Ministry of Finance:

-During the time of foreign contractor, foreign foreign contractors have not been given a tax-registration tax authority to declare, pay the GTGT tax in accordance with the deduction, if the Viet Nam pays money to foreign contractors, Foreign Contractors Contractors. Vietnam is responsible for deductible of the GTGT tax before payment. The amount of taxes filed by the total amount of payment has not included an increase in the value added tax (x) with the value added tax rate of goods to the goods, services provided by foreign contractors.

-When foreign contractors, foreign contractors are granted tax registration, foreign contractors, foreign contractors, bills of invoices, certificates from GGT's tax deposition to Vietnam. Except, pay for the GTGT tax on foreign contractors, foreign contractors.

Foreign contractors, Foreign Contractors are not deductible of the input GTGT tax on birth before being granted a tax registration certification.

Example 17:

In January 2015, foreign contractor A signed with Vietnam on the provision of oil and gas services for a $1 million contract. During the time the A foreign contractor had not yet been granted tax registration certification, the Foreign contractor A developed the first GTGT tax on goods, the purchase service to make a bid of $5,000. On March 15, 2015, Vietnam paid a payment to foreign contractor A with a value of $100,000 (not including the GTGT tax and which included the TNDN tax), Vietnam was responsible for filing a GTGT tax in place of the Foreign contractor A with the GGTGT tax confirmed. valuation of $100,000 by 10% = $10,000.

As of May 1, 2015, the Foreign contractor A registered and was granted tax registration certification. In May 2015, the Vietnamese side paid the Foreign contractor A with a value of $200,000 (which has not included the GTGT tax and has included the TNDN tax). Thus, the first GTGT tax issued by the Foreign contractor A was born in May of $20,000 (=200,000USD x 10%).

The GGTGT tax input from the A Foreign contractor A was born from 01/5/2015 to 30/5/2015 as $2,000 (GTGT tax born around the time the Foreign contractor A has had a tax code). Foreign contractor A transfer of the entire invoice, certificate from birth in May 2015 to the Vietnamese side to South Vietnam, filed in lieu of the GTGT tax of Foreign contractor A.

The value of the GTGT foreign contractor A must be submitted by the monthly GTGT tax declaration of $18,000 (= US$ 20,000-2000 USD).

Foreign contractor A was not deductible except for the $5,000 tax of the first GTGT in the pre-birth period of 01/5/2015.

Article 13. Corporate income tax

The tax base is the TNDN tax revenue and the ratio (%) the TNDN tax on tax revenues.

The TNDN tax must submit

=

TNDN tax revenue

x

The TNDN tax rate on tax revenue

1. TNDN Tax Revenue

a) TNDN tax revenues

The TNDN tax revenue is that the entire revenue does not include the GTGT tax that the foreign contractor, the Foreign Contractor Received, excluding the taxes that must be filed. The TNDN tax revenue is included in both the expenses paid by the Vietnamese side in lieu of foreign contractors, foreign subcontractors (if available).

b) Define the TNDN tax revenue for a number of specific cases:

b.1) The case, under the agreement at the contractor contract, the subcontractor contract, foreign contractor revenues, the Foreign Contractor Received not included the TNDN tax must submit, the TNDN tax collection is determined in the following formula:

TNDN tax revenue	=	Revenue does not include the TNDN tax
		1-TNDN tax rate on tax revenue

Example 18:

The foreign contractor A provides the Viet Cong to oversee mass surveillance of the Z cement plant, the contract price that has not included the GTGT tax, the TNDN tax of $285,000. In addition, the Vietnamese side arranged the accommodation and worked for the management staff of the foreign contractor with a value of $38,000 (not including the GTGT tax, TNDN). Under the contract, the Vietnamese side is responsible for paying the TNDN tax, the GTGT tax instead of foreign contractor. The identification of the foreign contractor TNDN tax must submit as follows:

Specifies tax revenue:

TNDN tax revenue	=	285,000 + 38,000	=	$340,000.
		(1-5%)

b.2) The case of foreign contractor signing contracts with the Vietnam subcontractor or foreign subcontractor does pay tax in accordance with a prescrip method or a Foreign Contractor in accordance with the mixed method of dealing with a portion of the work value or The category is regulated at the Contract of Contender with Vietnam and the list of Vietnamese subcontractors, foreign contractors who perform the work portion or the respective categories listed included under the Contract Contract, the Home Tax Revenue of TNDN. Foreign contractors do not include work value issued by the Vietnamese subcontractor or foreign subcontractor.

The case of foreign contractors contracted to provide suppliers in Vietnam to purchase raw materials, machinery to implement contractor and cargo contracts, services to serve internally, consumer non-item, The work that the foreign contractor does on a contractor contract is worth a commodity, and this service is not unless it is determined to determine the TNDN tax revenue of the foreign contractor.

Example 19:

Foreign contractor A signed a contract to build Z cement plant with Vietnam for a total contract value of $9 million (the price has not included the GTGT tax). According to the contractor Contract, the Foreign contractor A will hand over the portion of the construction value (stipulated at the contractor contract with Vietnam) to the Vietnamese subcontractor B with a value of $01 million (the price has not included the GTGT tax); in addition, during construction. set up the Z cement plant to implement the contractor contract, the foreign contractor A purchase of raw materials (bricks, cement, sand etc.) to implement construction and purchase of goods, services such as car rentals, hotels for professionals, purchasing stationery ... catering to the Make a deal.

The TNDN tax revenue of the foreign contractor A in this case is determined as follows:

Net tax revenues TNDN = $9 million-$1 million = $8 million

The TNDN tax revenue of the A foreign contractor A was not excluded from material capitalization, goods, services such as car rental, hotel rental to the expert, purchasing stationery ...

b.3) The case of foreign contractor contracting with Foreign Contractor Practices in accordance with the direct method of paying tax on a direct method, Vietnam pays TNDN tax in place of foreign contractor, Foreign Minister by rate (%) the TNDN tax on business. The tax rate corresponds to the business sector that the foreign contractor, the foreign contractor, is on the contract of the contractor, the subcontractor contract. Foreign subcontractor does not have to declare a TNDN tax on the portion of the work value of the Foreign Contractor Entity in accordance with the provisions at the contractor's contract with the Foreign contractor that the Vietnamese had filed instead.

b.4) TNDN tax revenue for machine leasing, equipment, transport is the full amount of rent. The case of machine rental revenue, equipment, transportation including expenses paid by the side directly paid such as media insurance, maintenance, registration certification, vehicle control, machinery and transportation costs. Equipment from overseas to Vietnam, TNDN tax revenue does not include these costs if there is evidence from reality.

b.5) The foreign airline ' s TNDN tax revenue is sales of passenger ticket sales, air transport and other revenues (except for state or institutional gains by law) in Vietnam for passenger transport, the company said. Other freight and other transportation objects were made on airlines ' own flights or in contact.

Example 20:

The foreign airline A in the first quarter of 2013 was a $100,000 sales, in which passenger ticket sales were $85,000, sales of $10,000 and MCO sales (from cost) of $5,000; simultaneously giving birth to $5,000. State procurement (airport fee) $1,000, the reimbursable reimbursable cost of $2,000.

The 2013 annual TNDN tax revenue of the foreign airline A was defined as follows:

Tax revenues TNDN = 100,000-(1,000 + 2,000) = $97,000

b.6) The foreign shipping company 's TNDN tax revenue is the entire amount of money obtained from passenger transport operations, freight, and other revenues that the marine carrier enjoyed from Vietnam' s shipping port to the last port of the country. The same cargo load (including the sum of the shipments must be transferred through the intermediate ports) and/or the proceeds are due to freight between the ports of Vietnam.

The money-based TNDN tax base does not include TNDN tax in Vietnam port for foreign owners and money paid for Vietnamese shipping business due to being involved in shipping from the port of Vietnam to a neutral port. Time.

Example 21:

Company A makes dealership for the foreign shipping company X. According to the transport contract, Company A on behalf of the X Company receives shipping abroad, releasing a single, collecting money for shipping ...

Vietnam's B business hired X Corporation (through Company A) to transport goods from Vietnam to the U.S. with $100,000.

Company A hired the shipping of Vietnam or overseas shipping from Vietnam to Singapore with a shipping deposit of $20,000 and from Singapore will be shipped to the United States by X.

The foreign X Transport Corporation's TNDN tax revenue is defined as follows:

TNDN tax revenue = 100,000-20,000 = $80,000

b.7) For the delivery service, the international depot from Vietnam to abroad, (not to distinguish the senor or the paid recipient), the TNDN tax revenue is the entire foreign contractor revenue received not including the required international shipping. Pay the carrier (aviation, sea).

b.8) For an international transfer service from Vietnam to foreign countries (not to distinguish it from deposers or payers), the TNDN tax revenue is the entire foreign contractor revenue received.

Example 22:

The overseas company provides mail delivery services from abroad to Vietnam and vice versa. The A Company ' s TNDN tax revenue is defined as follows:

+ For the overseas transfer service of Vietnam (which does not distinguish persons from overseas or recipient in Vietnam paid for service) is not part of the TNDN taxable income;

+ For service from Vietnam to foreign countries (not to distinguish persons in Vietnam or foreign recipient), the TNDN tax revenue is the entire Company A received.

Example 23:

Company B (Vietnam Company) provides mail delivery services from abroad to Vietnam and vice versa. To carry out this service, Company B payment (split) to the Company C in the country in addition to a sum of x USD. The Company C ' s TNDN tax is defined as follows:

+ For overseas transfer services to Vietnam (not to distinguish persons from overseas or recipient in Vietnam to pay the service), the $x Company of the Company C received not under the TNDN taxable income;

+ For the service of transfers from Vietnam abroad (not to distinguish persons in Vietnam or foreign recipient), the $x Company C received under the TNDN tax income; Company B is responsible for opening up, deductible, and more. filed a TNDN tax on the amount x payment for the Company C.

b.9) For reinsurance, TNDN tax revenues determined as follows:

-For foreign reinsurance operations, the TNDN tax revenue is the amount of foreign reinsurance to foreign contractors that the foreign contractor received (including reinsurance commissions and the cost of reimbursable customers by the agreement).

-For foreign reinsurance activity, the TNDN tax revenue is the reinsurance commission that the foreign contractor receives.

b.10) For the stock transfer, the TNDN tax revenue is defined as follows:

For securities transfers, deposit certificates, corporate income tax revenues are total stock sales, certificates of deposit at the time of transfer.

b.11) TNDN tax revenues on interest exchange transactions are the difference between the payable interest and interest that the foreign contractor received in a calendar year. The identification of the tax period according to the calendar year is carried out by regulation at the TNDN Tax Law, Tax Management Law and Guide documents.

Example 24:

Bank A (A) has a loan of $10 million with a fixed interest rate of 5.2% of the month. The contract period was three years from 1/2/2012 to 1/2/2015, the payment term payment of 6 months and payment at the start of the period.

On the basis of A loan contract of A, A negotiated with 1 bank B (B) abroad for the implementation of interest rate swaps, namely:

-The deadline for the implementation of the contract was 3 years from 1/2/2012 to 1/2/2015, the payment term of 6 January payment and payment at the start of the period.

-A float interest rate A must pay B is libor + 0.25% and B must pay a fixed interest rate of 5.2%. This means that if the interest rate libor + 0.25% is higher than the fixed interest rate under the swap contract the B receives a difference of interest rates from A calculated: (libor + 0.25%)-the interest is payable at a 5.2% interest rate. Conversely, if the libor rate + 0.25% is lower than the fixed interest rate under the swap contract, A receives a difference of interest rates from B as equals: 5.2%-interest A receives as per libor rate + 0.25%.

Payment times	Libor Interest (%)	A must pay B (%)	B must pay A (%)	After clearing an A or B interest received (%)		The amount of the difference A or B receives each term ($1,000m)
				A	B	A	B
1/2/2012-31/7/2012	4.80.	5.05	5.20.		0.15	-	15
1/8/2012-January 31, 2013	5.00	5.25.	5.20.	0.05		5
1/2/2013-31/7/2013	4.90	5.15.	5.20.		0.05	-	5
1/8/2013-January 31, 2014	4.95.	5.20.	5.20.	0.00		-	-
1/2/2014-31/7/2014	4.90	5.15.	5.20.		0.05		5
1/8/2014-January 30, 2015	5.05	5.30	5.20.	0.10		10

The determination of the TNDN tax revenue for B is as follows:

-2012 (January 1, 2012-December 31, 2012): The total number B received from A is: (15,000-5,000) = $10,000;

-2013 (from 01/01/2013-31 December 2013): The total number B received from A is: (5,000-0) = $5,000;

-2014 (from 01/01/2014-31 December 2014: B Did not receive the money but payment for A was $5,000 (Tax Revenue = 0);

-In 2015: Due to a contract payment agreement in the first term should not develop a clearing between A and B.

b.12) For the Treasury vote:

The identification of the TNDN tax revenue for treasury credits is applied to each type of treasury trust held by the investor at the time of the definite vote.

The TNDN tax revenue for treasury credits is defined as follows:

TNDN tax revenue

=

()

Treasury denominates

-

The average military price buys the number of treasury votes the investor holds on the expiration date.

)

x

The number of treasury credits the investor holds on the expiration date.

The calculation of the average purchase price of the number of treasury credits the investor holds at the time of the expiration is made in three steps:

Step 1: Define the number of holds of holds at a specified time.

Step 2: Define the quantity, time of purchase and the corresponding purchase price of the hold vote at the time of maturity (specified at step 1) in accordance with the previous purchase principle, the FIFO principle.

Step 3: Account of the license per capita in accordance with the formula:

= ∑ (the number of security checks at the time of maturity at the time purchase price x purchase at the time of purchase) ÷ Hold the amount of hold on hold at the time of maturity.

For example, 25: On January 1, 2015, the X Treasury trust issued a $100,000 release, a 6-month term issued for 89,000 shares. Immediately after the release, the Trust was listed and traded on HNX. Investor A made some of the following transactions from 2 January to 1/7/2015 (date of maturity):

Transaction date	Buy/Sell	Volume	Price
2/1/2015	Buy	100	90.000
1/2/2015	Buy	100	92.000
1/3/2015	Sold	70	93.000
1/4/2015	Buy	40	94.000
1/5/2015	Sold	20	95.000

Step 1: Define the number of holds held at a given time: (100 + 100 + 40)-(70 + 20) = 150 votes

Step 2: Define the number, time of purchase and the corresponding purchase price of the holding credits at the time of maturity after the number of the number of credits at the stock selling rules by which the previous purchase principle is sold first (the principle). FIFO): 150 votes in hold at the time of the expiration include:

+ 10 votes at a price of $90,000 on January 2, 2015.

+ 100 votes at a price of 92,000 buy on February 1, 2015.

+ 40 votes at a price of 94,000 purchased on 1 April 2015.

Step 3: Account of the license per capita in accordance with the formula:

Military pitcher buying credit: [(40 x 94,000 + 100 x 92,000 + 10 x 90,000 )/ 150] = 92,400 (bronze)

The TNDN tax revenue for the number of votes the investor received at a time of maturity: (100,000-92,400) x 150 = 1.140,000 (bronze).

2. Rate (%) the TNDN tax on tax revenue

a) Rate (%) the TNDN tax on tax revenues for the business sector:

STT	Business	Rate (%) TNDN tax on tax revenue
1	Trade: distribution, supply of goods, raw materials, supplies, machinery, equipment; distribution, supply of goods, materials, supplies, machinery, equipment attached to service in Vietnam {including offering goods in the form of export-based export-export form (excluding). case of public goods for the organization, foreign individuals); to provide goods under the delivery conditions of the International Trade Articles-Incoterms}.	1
2	Service, rental machinery, insurance, rig rental.	5
	Private: -Restaurant management services, hotels, casinos;	10
	-Student Financial Services.	2
3	Charter flights, flying boat engines, flying parts, sea ships	2
4	Build, install with a bid or not to bid for raw materials, machinery, equipment.	2
5	Manufacturing, other business, shipping (including sea transport, air transport)	2
6	Stock transfer, deposit certificate Oh, Reinsurance abroad, reinsurance and reinsurance.	0.1
7	Loan interest	5
8	Copyright income	10

b) Rate (%) the TNDN tax on tax revenues for certain specific cases:

b.1) For the contractor contracts, the subcontractor contract includes various business activities, the adoption of the TNDN tax rate on tax revenues when determining the TNDN tax number must submit to the TNDN taxable revenue for each operation. business by the Foreign contractor, the foreign contractor implemented by the regulation at the contract. The non-separate case that is valued at every business activity applies the TNDN tax rate to the business industry with the highest TNDN tax rate for the entire contract value.

For the construction activity, installation with materials or machinery, equipment accompanying construction work: The case of contract contractors separate from business operations, each part of the value of the work under contract. The percentage of the TNDN tax on revenue corresponds to that business activity. Where the contractor contract does not separate the value of business activity, the percentage of the TNDN tax on tax revenues is 2% across the entire contract value. The case of foreign contractor signing contracts with subcontractors to hand over the entire portion of the work value or category has a tenor of materials or machinery, equipment, foreign contractors only to implement the rest of the service value under contract. The contractor then rates the TNDN tax on the TNDN tax revenue applied to the service industry (5%).

Example 26:

Foreign contractor A signed a contract with Vietnam to build an X Power Plant with a value of $75 million (the price has not included the GTGT tax, but has included the TNDN tax).

Case 1: Contract of the contractor separate each business as follows:

+ The machine value, the supply device for the work: $50 million.

In it:

Machine value, device: $45 million

The warranty service value comes with machinery, equipment: $5 million.

+ Value of technology chain design, other design: $5 million.

+ Home value, other auxiliary system, installation construction activity: $15 million.

+ monitoring service value, installation guide: $3 million.

+ Technical training service value, test operation: $2 million.

The percentage of TNDN tax is applied as follows: for machine value of $45 million: 1%; for the operating value of construction, installation of $15 million: 2%; for the value of remaining services (warranty services, design, surveillance services, installation guidelines, and more). Technical training, testing, $15 million: 5%.

Case 2: The contractor contract does not separate the business, and the TNDN tax rate for the entire contract value of 75 million applies is 2%.

Case 3: Foreign contractor A contracted with subcontractors to hand over parts of the work that includes materials, the foreign contractor A only does the portion of the service value (e.g., the value of the monitoring service, the installation direction) then the share price. This service applies a rate of 5% to the TNDN tax.

b.2) For the contract to supply a device machine that is accompanied by existing services in Vietnam, if the separate separation is the value of the device and the value of the services, the tax rate is calculated according to the individual tax rate of each portion of the contract value. The case in the contract does not separate the value of the equipment and the value of the services, and the applicable TNDN tax rate on tax revenues is 2%.

For example, 27:

The foreign contractor A signed a contract with Vietnam to supply a machinery line, the device with a value of $70 million. The contract value includes:

+ Machine value, supply device for the work: $60 million

+ Value of technology chain design, other design: $5 million

+ monitoring service value, installation guide: $3 million

+ Technical training service value, test operation: $2 million.

In the case of separate separation of the device's machinery and the value of this service, the application of the TNDN tax rate is as follows: for machine value, the device applies rates to the commercial sector; for design service value, installation monitoring, training, and more. We ' re going to be able to do this, and we ' re going to try to apply the

The case is not separate, and the TNDN tax rate is 2% across the entire contract value ($70 million).

3. The TNDN tax on the amount of compensation obtained from the side of the contract violation to the case of the compensation clause is often greater than the damage value, which has taxable income:

For income from the damages compensation, foreign contractors are selected to account for the TNDN tax in accordance with the tax rate of TNDN on tax revenues or on a revenue basis basis, the cost of the tax rate is the common tax rate.

Section 4

THE GTGT TAX IS IN ACCORDANCE WITH THE DEDUCTION, PAYING TNDN BY PERCENTAGE COUNT ON REVENUE (the following is a mixed method)

Article 14. Applicable objects and conditions

Foreign contractors, Foreign Contractors, if you meet the two conditions at paragraph 1 and paragraph 2 Article 2 Chapter II and organize accounting accounting in accordance with the laws of accounting and guidelines of the Ministry of Finance are registered with the tax authority. implement the GTGT tax in accordance with the deduction and the TNDN tax in proportion to the rate of% on tax revenue.

Article 15. Value Value Tax

Follow in accordance with Article 9 Section 2 Chapter II.

Article 16. Corporate income tax

Performing in accordance with Article 13 Section 3 Chapter II.

Chapter III

THE ORGANIZATION.

What? 17.

1. This message has the enforcement effect since October 1, 2014, replacing the Digital Digital. 60 /2012/TT-BTC April 12, 2012 of the Ministry of Finance directed the implementation of the applicable tax obligation to the organization, the foreign individual business in Vietnam or its income in Vietnam.

2. The case of contracts, the subcontracting contract signed prior to this date of this date in effect, the identification of the GTGT tax obligation, the TNDN tax continues to perform as guidance in the corresponding law enforcement documents at the time of the signing of the contract.

3. The case at the International Convention that the Socialist Republic of Vietnam either signs or participate has stipulated that the taxpayer ' s tax return, the foreign foreign contractor with the guiding content at this Smart is done in accordance with the following regulations. It's the International Convention.

In the course of implementation if there is an entangrium, the organization suggests that the individual reflects promptly on the Ministry of Finance for the study of the ./.