Official Letter No. 5319/CT-CS dated July 28, 2026 of the Ministry of Finance on the determination of revenue subject to value-added tax and corporate income tax provides as follows:
by KMC Consulting Company Limited
The Double Taxation Avoidance Agreement between Vietnam and the United States has not yet entered into force; therefore, there is currently no basis for applying the provisions of the Agreement.Revenue for the calculation of value-added tax and corporate income tax during the 2023 and 2024 tax periods of the Company shall comprise the entire amount of proceeds from the sale of goods and provision of services received by the business establishment, including the amount of tax withheld in the United States.
In cases where the Company has paid corporate income tax in a foreign country and possesses tax payment documents as prescribed in Appendix 03-4/TNDN issued together with Circular No. 80/2021/TT-BTC, the Company may credit the amount of corporate income tax paid overseas against its corporate income tax payable in Vietnam, provided that the credited amount does not exceed the corporate income tax payable in Vietnam.In cases where the corporate income tax rate in the countries from which the enterprise remits income to Vietnam is lower, the difference shall be collected in comparison with the amount of corporate income tax calculated in accordance with the Vietnamese corporate income tax regulations.
