Official Letter No. 2200/CT-CS dated July 2, 2025, issued by the Tax Department regarding tax policy

In cases where foreign organizations or individuals supply goods in Vietnam under the form of on-the-spot import and export and generate income in Vietnam based on contracts signed with enterprises in Vietnam (excluding cases involving processing under entrustment and return ofgoods to the foreign organization or individual), or carry out the distribution of goods in Vietnam, or supply goods under delivery terms of international commercial terms (Incoterms) in which the seller bears the risk related to the goods until they enter the territory of Vietnam, such foreign organizations or individuals shall fall within the scope of application of Circular No. 103/2014/TT-BTC.

In contrast, where foreign organizations or individuals merely use bonded warehouses or inland container depots (ICDs) as storage facilities in support of international transportation, transshipment, transit, or for the purpose of storing goods or outsourcing processing to other enterprises, such foreign organizations or individuals shall not fall under the scope of application of Circular No. 103/2014/TT-BTC.

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