Nguyen Thuy Duong
Project Finance Advisor
Partner
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Project Finance Advisor
Partner
The Tax Department has issued specific guidance on corporate income tax (CIT) related to capital transfer activities in Official Letter No. 159/CT-CS, dated March 14, 2025.
On March 14, 2015, the Tax Department – Ministry of Finance issued an official letter addressing inquiries related to deductible expenses for corporate income tax (CIT) purposes. Specifically, the guidance pertains to the treatment of one-time lump-sum land rental payments and management fees for leased land that has not yet been utilized for production and business activities. The issue raised was whether land rental expenses for leased land that has not yet been put into use for business operations could be considered deductible when determining taxable income for CIT purposes.
Recently, the Ministry of Finance has announced and solicited public and business feedback on the draft Decree detailing the implementation of certain provisions of the Law on Value-Added Tax (“Draft”). The Draft introduces several noteworthy amendments, including the following:
On March 20, 2025, the Government issued Decree No. 70/2025/ND-CP (“Decree 70”), amending and supplementing several provisions of Decree No. 123/2020/ND-CP on invoices and documents (“Decree 123”), with the aim of updating regulations concerning the time of issuance of invoices for certain types of business activities. The key updates in Decree 70 include the following:
On April 9, 2025, the Ministry of Finance issued Official Letter No. 4525/BTC-PC to officially guide state management agencies and investors on how to determine areas eligible for investment incentives in the event of administrative boundary changes due to the reorganization and consolidation of administrative units. The Official Letter clarifies several important points as follows:
In the area of business registration, the Ministry of Finance issued Official Letter No. 4370/BTC-DNTN on April 9, 2025, providing guidance on business registration procedures following administrative boundary changes.
On April 2, 2025, the Government officially issued Decree No. 82/2025/NĐ-CP regarding the extension of deadlines for the payment of value-added tax (“VAT”), corporate income tax (“CIT”), personal income tax (“PIT”), and land rent in 2025 (“Decree 82/2025”). Some of the key points of Decree 82/2025 are as follows:
In order to implement the Government’s directive under Resolution No. 233/NQ-CP dated December 10, 2024, on supporting individuals and businesses in developing production and business activities, the Government is currently drafting the Draft Decree regulating the reduction of land rental fees for 2025 (“Draft”).
Attorney at Law
Senior Associate
Head Quarters
ALIAT Building, 27-31 D7 Street,
An Khanh Ward, Ho Chi Minh City, Vietnam
Tel: [+84] 1900.5555.38
Email: contact@aliat.group
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