Corporate income tax payable = taxable income x tax rate the corporate income tax 1. Income tax the income tax transfer Price =-costs have yet recovered investment-the cost assignment in which:-the transfer Price is the sum of the actual transfer value according to the contract of assignment.

The case of a contract of assignment stipulated the payment in the form of installment, deferred the transfer price is the sum of the actual transfer value according to the time limit prescribed in the contract of assignment does not include deferred interest, installment interest rate.

Transfer case not stipulated payment price or tax authorities have a basis to determine the rates of payment are not determined by market value, tax authorities have the right to inspect, request the parties to transfer provides information relating to the identification of current and future value of the exploration project mining, mineral processing, transfer before the parties decide the assignment, the assignee and assign the value of the payment of the contract on the basis of the market price, the reference price may be sold to a third party or the sale price of the contract of assignment.

-The cost was invested in projects of exploration, mining, mineral processing has not yet recovered is reasonable expenses under the provisions of the corporate income tax laws and the documents guiding the implementation defined on the basis of the books and vouchers as of the time of transfer, after deducting the costs were recovered. The cost was recovered as costs were charged to the taxable income to determine the number of corporate income tax payable before that.

The case of the Organization continue to transfer the right of exploration, mining, mineral processing, costs were investments in the project are determined by the value of the contract to the assignee immediately before additional costs plus more (if there is evidence from proven), minus the costs were recovered.

-Transfer costs include: costs to make the legal procedures necessary for the assignee; the fees and charges payable upon assignment; the transaction costs, negotiation, Contracting and other costs related to the transfer vouchers have demonstrated.

2. Tax rate of corporate income tax for the transfer of operating rights to the exploration, exploitation and processing of minerals is 25%.

3. Income from operations grant exploration, mining, mineral processing are separate accounting, do not enjoy preferential corporate income tax.

4. The transfer of project exploration, mining, mineral processing associated with the transfer of the property to a private accounting income from real estate transfer tax declaration according to the provisions of the corporate income tax laws and the documents guiding the implementation, not the offset to the income or losses of the business functioning.

Article 4. Personal income tax personal income from the transfer of operation rights of exploration, mining, mineral processing of personal income tax for income from the transfer of capital, namely: personal income tax payable = taxable income x tax rate 1. Income tax the income tax transfer Price =-costs have yet recovered investment-the cost assignment in which:-the transfer Price is the sum of the actual transfer value according to the contract of assignment.

The case of a contract of assignment stipulated the payment in the form of installment, deferred the transfer price is the sum of the actual transfer value according to the time limit prescribed in the contract of assignment does not include deferred interest, installment interest rate.

Transfer case not stipulated payment price or tax authorities have a basis to determine the rates of payment are not determined by market value, tax authorities have the right to determine the transfer prices pursuant to the law on tax administration and Law implementation guide text.

-The cost was invested in projects of exploration, mining, mineral processing has not yet recovered is reasonable costs related to the creation of taxable income from operations under the provisions of the personal income tax laws and the documents guiding the implementation defined on the basis of the books vouchers as of the time of transfer, after deducting the costs were recovered. The cost was recovered as costs were charged to the taxable income to determine the number of personal income tax payable before that.

Individual cases continued to transfer the right of exploration, mining, mineral processing, costs were investments in the project are determined by the value of the contract to the assignee immediately before additional costs plus more (if there is evidence from proven), minus the costs were recovered.

-Transfer costs include: costs to make the legal procedures necessary for the assignee; the fees and charges payable to the budget when the transfer procedures; other expenses directly related to the transfer, invoice, voucher valid.

2. The tax on personal income tax for income from capital transfer tax is 20% according to the provisions of article 17 of Decree 100/2008/ND-CP dated 8/9/2008 from the Government detailing a number of articles of the law on personal income tax.

3. Transfer of rights to the exploration, exploitation and processing of minerals are tied to property transfer, they must separate the income from transfer of property to enumerate the personal income tax for income from transfer of property under the provisions of the personal income tax laws and the documents guiding the implementation.

Article 5. About the taxes, fees, other fees taxes, fees, other fees made under the provisions of the law on taxes, charges and fees.

Article 6. Implementation of this circular are enforceable after 45 days from the date of signing. For the case of completed grant activities of exploration, mining, mineral processing prior to the time this circular has the effect that made no tax adjustments. The time of completion of the transfer of rights activities of exploration, mining, mineral processing is time of the parties in the contract of assignment is the competent authority that approved license.

The other content not this circular instruction is done in accordance with current tax law.

In the implementation process if there arise problems, suggest the Unit reports on the Finance Ministry to review the decision.