Official Letter No. 512/CT-CS dated April 9, 2025, issued by the Tax Department regarding tax policy is as follows

In the case where an enterprise sells the entire Single-Member Limited Liability Company (LLC) owned by an organization in the form of a capital transfer associated with real estate, the income from the capital transfer shall be handled in accordance with the provisions of Circular No. 78/2014/TT-BTC dated June 18, 2014, and the declaration and payment of corporate income tax (CIT) for the capital transfer activity shall be carried out in accordance with Circular No. 151/2014/TT-BTC dated October 10, 2014, issued by the Ministry of Finance (the cost of capital is not determined by deducting depreciation of fixed assets).

In cases where the purchase or sale price of the transferred capital is not determined based on the usual market transaction value, the tax authority may consider determining the tax amount by imposition, in accordance with Point đ, Clause 1, Article 50 of the Law on Tax Administration No. 38/2019/QH14 dated June 13, 2019.

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