1. Official Dispatch No. 832/CT-CS dated February 3, 2026 issued by the Tax Department regarding value-added tax (VAT) policy (in response to the Hanoi Tax Department).
On September 3, 2025, the Forestry and Forest Protection Department (under the Ministry of Agriculture and Environment) issued Official Letter No. 1616/LNKL-SDR in response to Official Letter No. 3229/CT-CS dated August 18, 2025 of the Tax Department, stating as follows: “Pursuant to Item 16101, Appendix II issued together with Decision No. 27/QD-TTg dated July 6, 2018 of the Prime Minister promulgating the Vietnam Standard Industrial Classification, activities such as sawing, cutting, planing, carving, and machining of wood are classified under the manufacturing and processing industry sector.”
Based on the above-mentioned regulations and guidance, the Tax Department agrees with the proposal of the Hanoi Tax Department stated in Official Letter No. 26993/CCTKV01-TTKT4 that agarwood wood chips produced from cultivated Aquilaria trees are processed wood products.
2. Official Dispatch No. 845/CT-CS dated February 4, 2026 issued by the Tax Department regarding value-added tax (VAT) policy (in response to the Lam Dong Provincial Tax Department).
In principle, if Tran Ngoc Bao Uyen Co., Ltd. satisfies the conditions for input VAT credit and VAT refund applicable to investment projects in accordance with VAT regulations, and submits a complete refund application dossier for the investment project in compliance with tax administration laws, it shall be eligible for consideration of a VAT refund for the investment project.
3. Official Dispatch No. 1001/CT-CS dated February 11, 2026 issued by the Tax Department regarding personal income tax (PIT) policy (in response to Ms. Pham Ngoc Tuyet Van).
In case Ms. Pham Ngoc Tuyet Van has already been issued a personal tax identification number and is subject to self-finalization for the 2017 personal income tax (PIT) refund, but did not include family circumstance deductions for her dependents (two biological children) in the 2017 tax year, she shall be entitled to claim deductions for such dependents (two biological children) from the month the obligation to support arose, provided that she registers the dependents for family circumstance deduction at the time of tax finalization.
In addition, according to the petition submitted by Ms. Pham Ngoc Tuyet Van, she had registered her two dependents (her biological children) with her former company from the years of their birth, in 2004 and 2013. However, based on the attached documents, the two dependents (her biological children) were issued tax identification numbers by the tax authority in November 2019.Ms. Pham Ngoc Tuyet Van is requested to contact the Ho Chi Minh City Tax Department for guidance on reviewing the dependent registration data and the 2017 PIT refund finalization dossier in accordance with regulations.
4. Official Dispatch No. 1052/CT-CS dated February 12, 2026 issued by the Tax Department regarding value-added tax (VAT) policy (in response to the Dak Lak Provincial Tax Department and Phu Yen High-Tech Dairy Farm Co., Ltd.).
In case the Company implements an investment project in multiple phases, with a business plan for producing pasteurized fresh milk products (without selling raw fresh milk), operates a closed production process (from dairy farming to obtain raw fresh milk through processing into pasteurized fresh milk products for sale, including outsourced processing of pasteurized fresh milk products), applies centralized accounting, and uses products not subject to VAT to produce goods subject to VAT, the input VAT incurred during the investment phase for the formation of fixed assets shall be fully creditable.
5. Official Dispatch No. 1061/CT-CS dated February 12, 2026 issued by the Tax Department regarding invoices (in response to the Ho Chi Minh City Tax Department).
In principle, where a taxpayer discovers errors or omissions in a tax return dossier already submitted to the tax authority, the taxpayer is permitted to file a supplementary tax return within 10 years from the expiry date of the filing deadline for the tax period in which such errors or omissions occurred, provided that this is done before the tax authority or a competent authority announces a decision on tax inspection or audit, or where the dossier does not fall within the scope or period of inspection or audit stated in the inspection or audit decision.
For matters falling within the scope of inspection or audit, the taxpayer may submit supplementary explanatory documents in accordance with tax laws, inspection laws, and in compliance with the conclusions or regulations of competent specialized authorities relating to the determination of the taxpayer’s tax obligations.
6. Official Dispatch No. 1063/CT-CS dated February 12, 2026 issued by the Tax Department regarding tax policy (in response to Vietnam Satellite Digital Television Co., Ltd.).
6.1. Determination of tax obligations for VSTV Company
Regarding Corporate Income Tax (CIT):
The Company shall recognize revenue for the purpose of determining taxable income as the total proceeds from the sale of goods, processing activities, and provision of services, including subsidies, surcharges, and additional fees to which the enterprise is entitled, regardless of whether payment has been received.In cases where the Company pays remuneration to Apple in connection with its production and business activities, and such payment is supported by lawful invoices and documents in accordance with regulations, the Company may record such amount as deductible expenses when determining taxable income in accordance with Article 4 of Circular No. 96/2015/TT-BTC.
Regarding Value-Added Tax (VAT):
In case VSTV Company provides television services in Vietnam, the VAT taxable price shall be determined in accordance with the guidance set out in Article 7 of Circular No. 219/2013/TT-BTC dated December 31, 2013 of the Ministry of Finance.
Where VSTV provides television service packages to customers in Vietnam, VSTV shall issue invoices to the customers and declare and pay taxes in accordance with applicable regulations.
In cases where VSTV has an agreement with Apple authorizing Apple to collect television service package fees on its behalf, VSTV shall recognize the total amount collected by Apple as VSTV’s revenue, issue VAT invoices to customers, and declare and pay VAT in accordance with regulations.
From July 1, 2025, VSTV Company shall implement the VAT policy in accordance with the Law on Value-Added Tax No. 48/2024/QH15 and its guiding documents.
From October 1, 2025, VSTV Company shall implement the corporate income tax (CIT) policy in accordance with the Law on Corporate Income Tax No. 67/2025/QH15 and its guiding documents, applicable from the 2025 tax period.
6.2. Determination of tax obligations for the foreign supplier Apple
As stipulated in Circular No. 80/2021/TT-BTC dated September 29, 2021 of the Ministry of Finance and Circular No. 103/2014/TT-BTC dated August 6, 2014 of the Ministry of Finance.
In case the foreign supplier Apple derives income in Vietnam by providing fee collection services from customers purchasing K+ service packages of VSTV Company and receives a remuneration of 15% of the package selling price under the agreement with VSTV, Apple shall declare and pay VAT and corporate income tax applicable to foreign contractors under the percentage method calculated on revenue with respect to the amount received by Apple, in accordance with Article 77 of Circular No. 80/2021/TT-BTC and Articles 12 and 13 of Circular No. 103/2014/TT-BTC.
As stipulated in the Law on Value-Added Tax effective from July 1, 2025.
From July 1, 2025, foreign organizations without a permanent establishment in Vietnam that provide services and generate revenue in Vietnam shall be subject to value-added tax (VAT) at the rate of 10%.
As stipulated in the Law on Corporate Income Tax effective from October 1, 2025, applicable from the 2025 tax period.
From October 1, 2025, where Apple generates income in Vietnam, it shall pay corporate income tax (CIT) at the rate of 5% on taxable revenue arising in Vietnam, applicable from the 2025 tax period.
7. Official Dispatch No. 1067/CT-CS dated February 12, 2026 issued by the Tax Department regarding value-added tax (VAT) (in response to the Hanoi Tax Department).
For the new investment project of 883-ZN-838 Co., Ltd. that satisfies the conditions for investment incentive sectors, the project shall be entitled to corporate income tax (CIT) incentives for the duration stated in the initial Investment Registration Certificate (05 years).For the extension period stated in the amended Investment Registration Certificate, the project shall not be entitled to tax incentives for the extended duration of the investment project.
8. Official Dispatch No. 1068/CT-CS dated February 12, 2026 issued by the Tax Department regarding value-added tax (VAT) (in response to the Hanoi Tax Department).
For the period prior to July 1, 2025, where Bihaco Trading and Media Services Joint Stock Company uses services provided by Google by uploading content (videos) to the YouTube platform and receives 55% of the advertising revenue generated from ads displayed on each of the Company’s videos under the YouTube Monetization Agreement, the total revenue paid to the Company by Google (YouTube) shall be determined as advertising revenue and shall be declared for value-added tax (VAT) at the tax rate of 10%.
From July 1, 2025, the Hanoi Tax Department is requested to guide the Company to implement the provisions of the Law on Value-Added Tax No. 48/2025/QH15 and its guiding documents.