📢 Dependent Accounting Representative Office – How to Declare Taxes Correctly?

The Hung Yen Province Tax Department has issued specific guidance under Official Dispatch No. 4946/HYE-QLDN2 dated December 1, 2025 regarding tax declaration for Dependent Accounting Representative Offices.

💡 Enterprise’s Situation

• Head office: Hung Yen
• Representative office established in Hanoi
• Dependent Accounting Representative Office does not conduct any business activities

❓ So the question is:
➡ Does a Dependent Accounting Representative Office have to separately declare and pay taxes?

⚖️ Official viewpoint of the Tax Authorities

🔎 1️⃣ Regarding the Legal Substance

• A Representative Office does not have a business function;
• A Representative Office is a unit dependent on the enterprise in accordance with the Law on Enterprises 2020.

💰 2️⃣ Value-Added Tax (VAT)

• A Representative Office is not a production facility;
• A Representative Office does not directly sell goods or generate revenue.

✅ Conclusion:
👉 A Representative Office is NOT required to separately declare Value-Added Tax.
👉 The enterprise carries out VAT declaration centrally at the Head Office.

🧾 3️⃣ Corporate Income Tax (CIT)

• A Dependent Accounting Representative Office is:
• Not a production facility;
• Not subject to Corporate Income Tax (CIT) allocation.

✅ Conclusion:
👉 A Representative Office is NOT required to submit a separate tax finalization return .
👉 The enterprise carries out Corporate Income Tax declaration and finalization centrally at the Head Office .

👥 4️⃣ Personal Income Tax (PIT)

• A Representative Office does NOT sign labor contracts ;
• A Representative Office does not directly pay wages to employees;
• The Head Office signs employment contracts and pays wages to employees.

✅ Conclusion:
👉 A Representative Office is NOT required to declare Personal Income Tax (PIT) .
👉 The enterprise carries out PIT withholding – declaration – payment for employees working at the Representative Office in accordance with the local allocation principles as stipulated in Circulars No. 80/2021/TT-BTC.

📌 Quick Summary

• ✔ A Representative Office does not conduct business activities → not required to separately declare taxes
• ✔ VAT & CIT → Tax declaration is carried out centrally at the Head Office
• ✔ PIT → The income-paying entity is responsible for tax declaration

🎯 Important Note

⚠️ Once a Representative Office meets any of the following conditions:

• Revenue is generated;
• Labor contracts are signed;
• Wages are paid directly;

➡ In such cases, the tax declaration method will change and the tax model must be reviewed immediately.

📞 MBA Auditing Firm

Specialized support for enterprises:

• Review of the Representative Offices – Branches operating model;
• Advisory on multi-province and multi-locality tax declaration;
• Pre-inspection tax risk review.

👉 Contact MBA Audit to have your company’s Representative Office model reviewed to determine whether it complies with regulations or poses potential tax risks.