Tax Newsletter. September For reference only, not to be distributed, or sold

Transcription

1 Tax Newsletter September 2018 For reference only, not to be distributed, or sold

2 NEW REGULATIONS New regulations on electronic invoicing Import tax exemption procedure according to International Agreements and Treaties New List of special commodities entitled to AKFTA preferential tax rates GUIDING DOCUMENTATIONS Corporate Income Tax ( CIT ) Conditions for changing fixed asset ( FA ) depreciation method Provision for financial investment loss if the capital investees suffer from losses Personal Income Tax ( PIT ) No PIT on profit distributed to individual being the owner of one-member limited liability companies PIT declaration and finalization at branches Housing allowance included in bonus is also capped at 15% for PIT purposes PIT on dividends paid in shares to individuals Severance allowance paid higher than regulated in laws is subject to PIT Promotional gift redeemed for cash is subject to PIT Foreign Contractor Withholding Tax ( FCWT ) FCWT on intermediary payment service via MoMo e-wallet FCWT on contract compensation Value Added Tax ( VAT ) Debt trading between the company and its branch is not exempted from VAT Land value is deducted from purchase price when determining VAT on the transfer of real estate Related party transactions Companies having related party transactions must prepare, maintain and provide Group Master file Tax administration Revisions of invoice usage report before tax audit will not be penalized The business owner of an absconded company is still compelled to pay tax debts No late payment interest during PIT relief period Customs Supplementary declaration for late submission of certificates of origin ( C/O ) Notification of manufacturing facilities to new managing Customs Sub-department Deadline for supplementary of C/O is counted continuously Application priorities for goods classification based on HS Nomenclature Products purchased for export should be registered under trading mode upon export Post-clearance supplementation of documents is temporarily accepted for e-customs declaration Answers to some questions related to C/O Change line to check physical goods and determine name of goods Entrusted import of automotive components (group 98.49) enjoys 0% duty rate Trading activities of FDI enterprises

3 NEW REGULATIONS New regulations on electronic invoicing On 12 September 2018, the Government issued Decree No. 119/2018/ND-CP ( Decree 119 ) on the use of electronic invoice ( e-invoice ) when selling goods and providing services. Accordingly, all businesses, economic organizations and other organizations are required to issue e-invoices when selling goods and providing services irrespective of the value of each transaction. E-invoices include VAT invoice, sales invoice, stamps, tickets, electronic receipts and other electronic documents which having the contents of e-invoices. There are two (02) types of e-invoices: e-invoices with verification code of the Tax authorities and e-invoices without verification code of the Tax authorities. or are going to transact with the tax authorities via electronic means, and meet the requirement on information technology infrastructure and software systems. Enterprises required to use e-invoices with verification code of the Tax authorities include high tax risk enterprises, enterprises who voluntarily register to use, and other business individuals and households. Taxpayers register to use e-invoices either with or without verification code on the web portal of the General Department of Taxation by filling in Form 01 of the Appendix to this Decree. Tax offices shall notify taxpayers of the acceptance or non-acceptance of using e-invoices within 01 working day after receiving the registration. E-invoices without verification code of the Tax authorities are applied to enterprises in certain fields such as electricity, petroleum, aviation, water supply, banking, etc.; and those who have been transacting For reference only, not to be distributed, or sold 2018 Deloitte Vietnam Tax Advisory Co. Ltd. 3

4 Decree 119 takes effect from 01 November Enterprises already registered to use e-invoices with or without verification code before the effective date continue using such e-invoices. During the transition period from 01 November 2018 to 31 October 2020, enterprises had registered the issuance of the paper invoices may continue using such invoices in accordance with Decree No. 51/2010/ND-CP and Decree No. 04/2014/ND-CP. For more details of changes and new regulations under Decree 119, please refer to Deloitte Vietnam s Tax Alert released on 18 September Import tax exemption procedure according to International Agreements and Treaties The General Department of Customs promulgates Decision No. 2503/QD-TCHQ ( Decision 2503 ) dated 23 August 2018 on the process of handling import tax exemption under international agreements or treaties between Vietnamese Government and non-governmental organizations. Some noteworthy points in Decision 2503 are as follows: Tax Policy Division under Import-Export Tax Department shall be assigned to handle the dossiers. Where international agreements and treaties do not regulate the types and quantities of tax exempted goods, Customs shall consult the Ministry of Foreign Affairs on the types and quantities of tax exempted goods. After being accepted by the Ministry of Foreign Affairs, Customs shall prepare reports to the Prime Minister for decision on the types and quantities that are tax exempted. Customs will provide a list of import tax exempted goods to provincial Customs Departments (where the taxpayer is headquartered) for issuance of a tracking slip on the quantities of such tax exempted goods. The Decision came into effect 15 days after its signing date Deloitte Vietnam Tax Advisory Co. Ltd. For reference only, not to be distributed, or sold 4

5 GUIDING DOCUMENTATIONS New List of special commodities entitled to AKFTA preferential tax rates On 14 September 2018, the Ministry of Industry and Trade issued Circular No. 26/2018/TT-BCT, amending and supplementing Circular No. 20/2014/TT-BCT dated 25 June 2014, on the implementation of Rules of origin in the ASEAN Korea Free Trade Area Agreement ( AKFTA ). Specifically, the Circular provides a new Annex IV specifying on the list of special commodities to be applied under the Rules of origin when considering the conditions for enjoying AKFTA preferential tax rates under provisions of Article 6, Annex I, Circular No. 20/2014/TT-BCT. This Circular will take effect from 29 October 2018 and abolishes previous Annex IV attached with Circular No. 20/2014/TT-BCT. Corporate Income Tax ( CIT ) Conditions for changing fixed asset ( FA ) depreciation method On 21 August 2018, the General Official Letter No. 3228/TCT-DNL guiding the determine of depreciation amount when changing FA depreciation method. Accordingly, in case there is no change in FA useful life and no improvement or upgrading activities to extend the useful life of FA compared to its original status, in order to change FA depreciation method, the company must ensure: Condition: the change of depreciation method does not change the company s business result from profit position into loss position or vice versa at the year the changing decision is made; and Depreciation for each remaining period is equal to remaining value of FA divided by remaining useful life of FA (if there is no change in such useful life in comparison with the original estimation). For reference only, not to be distributed, or sold 2018 Deloitte Vietnam Tax Advisory Co. Ltd. 5

6 Provision for financial investment loss if the capital investees suffer from losses On 29 June 2018, Ho Chi Minh City Tax Department issued Official Letter No. 6315/CT-TTHT guiding the provisions for long-term investments. Accordingly, when a company makes capital contributions to other companies (counterparty), in principle, if business result recorded in the financial statements of the counterparty is at a loss position (this loss must not be the loss foreseen in the business plan made before investment) and total actual investment capital of the company is higher than the total equity of the counterparty at the issuance time of the financial statement, the company can make provision for long-term financial investment based on the counterparty s accounting balance sheet and this provision would be treated as deductible expense for CIT purposes. Personal Income Tax ( PIT ) No PIT on profit distributed to individual being the owner of one-member limited liability companies On 04 September 2018, the General Official Letter No. 3387/TCT-CS guiding PIT policy. Accordingly, in case a one-member limited liability company is established by an individual under Enterprise Law, from 01 January 2015 profits after corporate taxes distributed to that individual will not subject to PIT. PIT declaration and finalization at branches On 27 August 2018, the General Official Letter No. 3291/TCT-TNCN guiding PIT declaration and finalization at branches. Accordingly, the responsibility to withhold and make PIT payments belongs to the direct paying body. For employees working at branches, if the branch directly pays salary, then it has to withhold and pay PIT for its employees. If the parent company is the direct paying body, then it is required to withhold and make PIT payments Deloitte Vietnam Tax Advisory Co. Ltd. For reference only, not to be distributed, or sold 6

7 Housing allowance included in bonus is also capped at 15% for PIT purposes On 23 August 2018, the General Official Letter No. 3256/TCT-TNCN guiding PIT on housing allowances that the company paid on behalf of its employees. Accordingly, when the company pays bonus to employees including housing allowances, such housing allowances shall be included in incomes from salaries and wages for PIT calculation but the taxable threshold shall not exceed 15% of total taxable income. PIT on dividends paid in shares to individuals On 20 August 2018, the General Official Letter No. 3206/TCT-CS guiding PIT on dividends paid by shares to individuals. Accordingly, dividends paid in form of shares are not required to declare capital investment tax at the time receiving shares. However, when transferring these securities, individuals must declare and pay PIT on both capital investment income and securities transfer income. For reference only, not to be distributed, or sold Income from capital investment: The individual is responsible for declaring and paying PIT on income from capital investment. The company has no responsibility to withhold or pay taxes. Income from securities transfer: In case the shares belong to public company trading at Stock Exchange, individuals are not required to directly declare and pay the tax. Instead, the securities companies or commercial banks where individuals opened custody account, or the fund management company where the investment portfolio is managed, will be responsible for PIT declaration. Severance allowance paid higher than regulated in laws is subject to PIT On 05 July 2018, Ho Chi Minh City Tax Department issued Official Letter No. 6553/CT-TTHT guiding PIT on the amount of severance allowance paid higher than regulated, specifically: The amount of severance allowance paid to employees in accordance with the Labor Code is exempted from PIT; 2018 Deloitte Vietnam Tax Advisory Co. Ltd. 7

8 The extra amount of severance allowance paid to employees, which is not in accordance with Labor Code and Social Insurance Code (extra paid) is subject to PIT. In case, the company pays salary, bonuses and allowances after termination date of the labor contract, it has to withhold PIT at 10% rate applied to wages, salary and other incomes paid to tax resident individuals who do not sign a labor contract. The employee shall be responsible for re-determining his PIT obligation on incomes being withheld by the company at year-end when making direct PIT finalization with the tax office. Promotional gift redeemed for cash is subject to PIT On 12 June 2018, Ho Chi Minh City Tax Department issued Official Letter No. 5509/CT-TTHT guiding tax policies for promotional gifts for customers. Accordingly, where the company carries out a travel tour promotion program for customers achieving sales target, in case the customers are business households or individuals, if they decide not to participate in the tour but redeem for cash instead, when paying this amount, the company must withhold PIT at the rate of 1% applied to income from other activities of business individuals Deloitte Vietnam Tax Advisory Co. Ltd. For reference only, not to be distributed, or sold 8

9 For PIT declaration on behalf of customers, the company shall use Form 01/CNKD promulgated in Circular No. 92/2015/TT-BTC and specify the phrase "Declaration on behalf" before the phrase "Taxpayer". Foreign Contractor Withholding Tax ( FCWT ) FCWT on intermediary payment service via MoMo e-wallet On 07 September 2018, the General Official Letter No. 3428/TCT-CS guiding FCWT declaration and payment for intermediary payment service of MoMo e-wallet. Accordingly, in case foreign companies provide intermediary payment service via MoMo e-wallet for transactions of sales or purchase of goods and services, FCWT treatment in terms of incomes earned from transaction processing fees paid by the seller of goods and services is as follows: For transactions that both seller and buyer are in Vietnam: The fee that foreign companies received by the seller of goods and services in Vietnam is subject to FCWT. At the same time, the supplier is responsible for withholding FCWT before remitting transaction processing fee to the foreign company. For transactions that seller is foreigner and buyer is in Vietnam: Transaction processing service fees paid by the foreign supplier would not be subject to FCWT. FCWT on contract compensation On 06 July 2018, Ho Chi Minh City Tax Department issued Official Letter No. 6600/CT-TTHT guiding tax policies for contract compensation. Accordingly, in cases where foreign companies receive compensation arisen from purchase contracts with companies in Vietnam, such compensation amount is subject to FCWT at CIT - 2% and VAT-exempt. Technically, Vietnamese company paying the compensation shall be responsible for withholding FCWT on behalf of the foreign party. For reference only, not to be distributed, or sold 2018 Deloitte Vietnam Tax Advisory Co. Ltd. 9

10 However, if the Vietnamese company does not withhold tax, and at the same time, the foreign party authorizes another third party in Vietnam to collect such compensation, the third party shall be responsible for withholding and paying FCWT on behalf of the foreign party. Value Added Tax ( VAT ) Debt trading between the company and its branch is not exempted from VAT On 27 August 2018, the General Official Letter No. 3300/TCT-DNL guiding tax liabilities for the transfer of assets between the company and the branch. Accordingly, where a branch transfers all its assets and account payables to the parent company through a purchase contract or an agreement on the transfer of assets and account payables, such transfer shall not be considered as business type transformation. Consequently, the branch shall not be exempted from tax declaration but required to pay VAT. company under the above purchase contract or agreement, such losses shall not fall into cases that are allowed to be carried forward under the rule of 5 consecutive years. Land value is deducted from purchase price when determining VAT on the transfer of real estate On 13 August 2018, Ho Chi Minh City Tax Department issued Official Letter No. 7981/CT-THT guiding VAT on real estate transfer activities. Specifically, where a company buys land from individuals; invests in infrastructure, splits the purchased land into lots, then transfer the land use rights of such lots to other individuals, the land use rights shall not be subject to VAT. As a result, value of land use right can be deducted from the transfer price when calculating VAT. The deductible land value for VAT purposes is the price of such land use right at the point of time when the land use right is transferred. Regarding the accumulated losses (if any) of the branch, when being actually transferred to the parent 2018 Deloitte Vietnam Tax Advisory Co. Ltd. For reference only, not to be distributed, or sold 10

11 Related party transactions Companies having related party transactions must prepare, maintain and provide Group Master file On 16 August 2018, the General Official Letter No. 3170/TCT-TTr answering questions on the implementation of Decree No. 20/2017/ND-CP dated 24 February 2017 and Circular No. 41/2017/TT-BTC dated 28 April 2017 of the Ministry of Finance. Specifically, related party transaction dossiers, including Group Master file, must be prepared by taxpayers under Decree No. 20/2017/ND-CP before the deadline of tax finalization and kept at the taxpayer s site. The taxpayers are obliged to provide these dossiers to Tax authorities when requested. Tax administration Revisions of invoice usage report before tax audit will not be penalized On 15 August 2018, General Official Letter No. 3142/TCT-DNL guiding invoice usage report. Accordingly, if a company finds out that the invoice usage report submitted was incorrect, and had submitted a revised invoice report before the Tax authority issues the audit or inspection decision, then it shall not be penalized. The business owner of an absconded company is still compelled to pay tax debts On 17 August 2018, the General Official Letter No. 3185/TCT-QLN on collecting of tax debts of absconed companies. Accordingly, when a company leaving its business address does not carry out dissolution or bankruptcy procedures, the business owner shall still be responsible for the remaining tax debts. If the business owner fails to fully paid tax debts over 90 days after the payment deadline, Tax For reference only, not to be distributed, or sold 2018 Deloitte Vietnam Tax Advisory Co. Ltd. 11

12 authorities shall have the right to apply measures to recover those debts. However, depending on the type of absconded business, the owner of the business will be responsible for the payment of tax debts in different levels, such as within the amount of capital contributed, charter capital or the entire assets of the business owner. No late payment interest during PIT relief period On 15 August 2018, the General Official Letter No. 3141/TCT-TNCN on no late payment interest applied during PIT relief period. Accordingly, penalty for late payment shall be applied only after the expiration of tax relief period when taxpayers have to pay tax to the State budget. If taxpayers fail to pay full tax liabilities after the tax relief period ended, they shall bear late payment interests and be forced to comply with tax administrative decisions. Customs Supplementary declaration for late submission of certificates of origin ( C/O ) Pursuant to Clause 2, Article 5, Circular No. 38/2018/TT-BTC, if the C/O has yet to be submitted at the time carrying out customs procedures, customs declarants should note about late submission of C/O on e-customs declaration form. When supplementing the C/O at post customs clearance, customs declarants fill in C/O reference number and issuance date on the supplementary declaration form. Accordingly, at the time carrying out customs procedures, if no late submission of C/O is noted while the goods have physically passed through customs clearance, companies are not allowed to make amendment to the declaration and then to supplement the C/O. Above is the guidance in Official Letter No. 2351/GSQL-GQ4 issued by the General Department of Customs dated 01 August Deloitte Vietnam Tax Advisory Co. Ltd. For reference only, not to be distributed, or sold 12

13 Notification of manufacturing facilities to new managing Customs Sub-department On 02 August 2018, the General Department of Customs issued Official Letter No. 2370/GSQL-GQ1 guiding cases where the company changed its managing Customs Sub-department. Specifically, when changing Customs Sub-department, the company must notify about its manufacturing facilities to the new managing Customs Sub-department, including all information related to the production plant, Government inspections and other information on law compliance. The former Customs Sub-department shall discuss and provide all information related to the company to the new one, including finalization reports on usage of raw materials, supplies, machines, tools, equipment and goods for export; compliance status; tax obligations, incomplete customs procedures (if any); and other information collected up to the date of such change. On 23 August 2018, the General Department of Customs issued Official Letter No. 4943/TCHQ-GSQL on supplementary of C/O. According to Official Letter No /BTC-TCHQ dated 04 October 2016, if there is no official C/O at the time of customs clearance, the company shall declare the supplement of C/O on customs declaration form and submit C/O within 30 days from registration date of such declaration form. The 30-day period from registration date is not 30 working days but counted on a continuous basis, including weekend days off and public holidays. Application priorities for goods classification based on HS Nomenclature On 23 August 2018, the General Department of Customs issued Official Letter No. 4880/TXNK-PL guiding the classification of HS code for imported goods, specifically: Deadline for supplementary of C/O is counted continuously For reference only, not to be distributed, or sold 2018 Deloitte Vietnam Tax Advisory Co. Ltd. 13

14 On the applicable description in the list of exported and imported goods in Vietnam: The Vietnamese list of exported and imported goods is formulated in full compliance with the HS Nomenclature of the World Customs Organization (6-digit code) and the ASEAN Harmonized Tariff Nomenclature (8-digit code). However, when there isdifference in description of goods between the Vietnamese list and the HS Nomenclature, then description of goods shall follow the HS Nomenclature; On the HS code classification: The HS code classification must be based on customs records, technical documentation, physical information, chemical composition, properties, features, functions and utility of exported or imported goods. In order to determine the HS code with certainty, companies may request for advance ruling on HS code classification in accordance with Circular No. 39/2018/TT-BTC before carrying out customs procedures. Products purchased for export should be registered under trading mode upon export On 29 August 2018, the General Department of Customs issued Official Letter No. 2705/GSQL-GQ2 guiding customs procedures in cases of selling products to other enterprises for export. Specifically, pursuant to guidance of the Law on Export-Import Duties and Decree No. 134/2016/ND-CP, in case where an enterprise imports goods to produce export goods but does not directly export the products but sells to other enterprises to export, the imports would not be eligible for duty exemption or refund on import duty paid. Accordingly, those enterprises purchasing products made from imported materials would have to carry out customs procedures under trading mode upon export. Post-clearance supplementation of documents is temporarily accepted for e-customs declaration On 19 September 2018, the General Department of Customs issued Official Letter No. 5459/TCHQ-GSQL guiding cases where the system is not able to receive customs dossiers submitted by customs declarants. Specifically: 2018 Deloitte Vietnam Tax Advisory Co. Ltd. For reference only, not to be distributed, or sold 14

15 For customs declarations under red and yellow lines: Enterprises have to submit/ present documents in hard copy to conduct customs procedures and clearance of goods; For declaration form under green lines: Enterprises have to submit customs dossiers after clearance within 5 days from the customs clearance date. In order to avoid system outage, provincial customs departments should notify and recommend customs declarants to upload additional documents under green line declaration out of business hours or during public holidays. The above is temporary solution and only applicable until system issues are resolved. Answers to some questions related to C/O On 25 June 2018, the Ministry of Industry and Trade issued Official Letter No. 4992/BCT-XNK to answer some questions related to content of Decree No. 31/2018/ ND-CP. Specifically: Regarding the use of e-customs declaration forms in C/O issuance application procedures: According to Clause 9, Article 25, Decree No. 08/2015/ND-CP, enterprises are allowed to use e-customs declaration forms and do not have to print out and submit printed declaration forms when carrying out C/O issuance application procedures for exported goods. However, according to the Ministry of Industry and Trade, the current look-up for e-customs declaration form in system often occurs errors, causes delay in documentation processing time; therefore, C/O application dossiers stipulated in Article 15 of Decree No. 31/2018/ND-CP are still required to be submitted in hard copy. Regarding self-certified C/O According to provisions of Article 25, Decree No. 31/2018/ND-CP, if traders qualify for a number of selective criteria under International Treaty or some criteria prescribed by importing country guided by the Ministry of Industry and Trade, they would For reference only, not to be distributed, or sold 2018 Deloitte Vietnam Tax Advisory Co. Ltd. 15

16 self-certify the origin of goods exported from Vietnam, not limited to agricultural or industrial goods. Change line to check physical goods and determine name of goods On 03 August 2018, the General Department of Customs issued Official Letter No. 2389/GSQL-GQ1 guiding the inspection of imported goods, specifically: Regarding the change of line to conduct physical goods inspection: Customs authorities may decide to change line to check physical goods, if: during the detailed review of customs documents, inaccurate, incomplete or inconsistent contents between customs declarations and related customs documents, are detected; there are signs of non-compliance in goods control policies, tax regulations on imported and exported goods or other rulings. Regarding the inspection for goods identification, category: Customs authorities may request for additional submission of technical documents, or purchase contracts, or component analysis report for their basis of goods identification, where: the information about goods identity and description declared in customs declaration forms are different from other documents of the customs dossiers: or There is not having enough information to name the goods. When it is impossible to determine the exact name of goods and codes, Customs authorities, together with declarants, have to take samples for further testing and analysis, follow guidance of the Ministry of Finance on goods classification, in order to accurately determine name of the goods. Entrusted import of automotive components (group 98.49) enjoys 0% duty rate 2018 Deloitte Vietnam Tax Advisory Co. Ltd. For reference only, not to be distributed, or sold 16

17 On 15 August 2018, the General Department of Customs issued Official Letter No. 4799/TCHQ-TXNK guiding the implementation of Import duty incentives program for automobile components and parts, specifically: Where an automobilemanufacturing company ( trustee ) has registered for the Import duty incentive program and entrust the import of automobile components to another company ( trusted ), upon the usage finalization, the Customs authorities will refund overpaid duty amounts to the trustee's bank account if it fully satisfies the conditions for enjoying 0% duty rate as stipulated in Decree No. 125/2017/ND-CP. Note: the trusted company has to submit a written request for refund of the overpaid duty into the trustee s bank account. of automobiles in the subsequent period (the next finalization period) will not be entitled to 0% duty rate. This official letter replaced the guideline on transferring outstanding components to the next period at Point 1, Official Letter No. 3782/TCHQ-TXNK dated 28 June 2018 of the General Department of Customs. Trading activities of FDI enterprises Recently, the Ministry of Industry and Trade has issued a number of official letters guiding trading activities of FDI enterprises according to Decree No. 09/2018/ND-CP such as Official Letter No. 6219/BCT-KH dated 07 August 2018 and Official Letter No. 6219/BCT-KH dated 07 August Specifically, some noteworthy points include: Regarding the handling of ending balance quantity of imported components: Any imported components that remained from the previous period (the previous finalization period) that have been used for manufacturing, assembling For reference only, not to be distributed, or sold 2018 Deloitte Vietnam Tax Advisory Co. Ltd. 17

18 Sales of goods to other traders or organizations not for retail or consumption are considered as wholesale activities. Sales of goods to organizations for consumption, internal use of such organizations, not directly use in production process or for service implementation under registered investment objectives and business activities, are considered as retail activities. The wholesale and retail distribution of goods manufactured by FDI enterprises in Vietnam according to the objectives of the registered investment projects are not regulated under Decree No. 09/2018/ND-CP. Therefore, FDI enterprises are not required to carry out procedures for applying for business license or retail establishment license when performing these activities. Decree No. 09/2018/ND-CP does not contain compulsory provisions on whether the list of retail goods must be declared using HS codes, appellations, or chapters for foreign invested entities. The licensing department (Department of Industry and Trade) provide contents of goods in the business license, retail establishment license based on the application dossier of the economic organization, in line with the assessment and verification of the Department of Industry and Trade Deloitte Vietnam Tax Advisory Co. Ltd. For reference only, not to be distributed, or sold 18

19 Contacts Thomas McClelland National Tax Leader Tel: Bui Ngoc Tuan Tax Partner Tel: Bui Tuan Minh Tax Partner Tel: Phan Vu Hoang Tax Partner Tel: Dion Thai Phuong Tax Partner Tel: Dinh Mai Hanh Tax Partner Tel: Suresh G Kumar Tax Partner Tel: ksuresh@deloitte.com Vo Hiep Van An Tax Partner Tel: avo@deloitte.com Hanoi 15 th Floor, Vinaconex Tower, 34 Lang Ha Street, Dong Da District, Hanoi, Vietnam Tel: Fax: Ho Chi Minh City 18 th Floor, Times Square Building, 57-69F Dong Khoi Street, District 1, Ho Chi Minh City, Vietnam Tel: Fax: Website: deloittevietnam@deloitte.com For reference only, not to be distributed, or sold 2018 Deloitte Vietnam Tax Advisory Co. Ltd. 21

20 Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited ( DTTL ), its global network of member firms, and their related entities. DTTL (also referred to as Deloitte Global ) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see to learn more. Deloitte is a leading global provider of Consulting, Financial Advisory, Risk Advisory, Tax, Audit & Assurance, and related services. Our network of member firms in more than 150 countries and territories serves four out of five Fortune Global 500 companies. Learn how Deloitte s approximately 264,000 people make an impact that matters at About Deloitte Southeast Asia Deloitte Southeast Asia Ltd. a member firm of Deloitte Touche Tohmatsu Limited comprising Deloitte practices operating in Brunei, Cambodia, Guam, Indonesia, Lao PDR, Malaysia, Myanmar, the Philippines, Singapore, Thailand and Vietnam was established to deliver measurable value to the particular demands of increasingly intra-regional and fast growing companies and enterprises. Comprising approximately 340 Partners and 8,800 professionals in 25 office locations, the subsidiaries and affiliates of Deloitte Southeast Asia Ltd. combine their technical expertise and deep industry knowledge to deliver consistent high quality services to companies in the region. All services are provided through the individual country practices, their subsidiaries and affiliates which are separate and independent legal entities. About Deloitte Vietnam Deloitte Vietnam, a pioneer in the Advisory and Audit industry with over 27 years of experience in the Vietnam market, is part of the global Deloitte network, one of the Four largest professional services organisations in the world. Our clients are served by over 900 staff located in our Hanoi and Ho Chi Minh City offices but also enjoy access to the full strength of our Deloitte Southeast Asia member firm with practices in Brunei, Cambodia, Guam, Indonesia, Lao PDR, Malaysia, Myanmar, the Philippines, Singapore and Thailand. Through our extensive network, Deloitte Vietnam delivers value-added services in Tax, Financial Advisory, Risk Advisory, Audit & Assurance and Professional Training Services to the private and public sectors across a wide range of industries.

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