📢 TAX DEPARTMENT RESPONDS ON THE 0% VAT RATE
FOR ON-THE-SPOT IMPORT/EXPORT GOODS
📅 On 1 July 2026, The Tax Department issued Official Letter No. 4425/CT-CS in response to the
Korean Chamber of Commerce in Vietnam (KOCHAM) regarding VAT treatment for on-the-spot import/export activities.
🔎 Below are the key points enterprises should note:
1️⃣ Conditions for applying the 0% VAT rate
📌 Exported goods are eligible for the 0% tax rate only when all prescribed conditions are fully satisfied, including:
- 📄 Sales or processing contracts for export goods;
- 🏦 Bank payment documents;
- 🛃 Appropriate customs declarations;
- ✅ Other related conditions.
⏳ For transactions arising before 1 July 2025, the determination of on-the-spot import/export goods
should be considered in accordance with the regulations in force at the time the transaction arose.
📖 From 1 July 2025, Law No. 90/2025/QH15 adds Article 47a to the Law on Customs, providing a clearer legal basis
for on-the-spot import/export goods.
2️⃣ Tax refund dossiers are reviewed based on each
enterprise’s specific case
📝 The Tax Department emphasizes that tax refunds fall under the authority of the directly managing tax authority
and must be reviewed based on each specific dossier.
📂 Therefore, enterprises should provide a complete set of supporting documents, including:
- 📄 Contract;
- 🛃 Customs documents;
- 🏦 Payment documents;
- 📑 Documents for each transaction and each tax refund period.
⚠️ A general petition submitted through an association does not replace the review of each enterprise’s specific dossier.
✅ What should enterprises do?
👉 Enterprises engaging in on-the-spot import/export transactions should:
- ✔ Review the validity of customs declarations, especially for transactions arising before 1 July 2025;
- ✔ Check all conditions for applying the 0% VAT rate;
- ✔ Prepare supporting documents for each transaction and VAT refund period;
- ✔ Proactively work with the directly managing tax authority when issues arise.
📌 Conclusion
Official Letter No. 4425/CT-CS indicates that the application of the 0% VAT rate and the processing of VAT refunds
for on-the-spot import/export goods will be considered based on the regulations in force at each relevant time and
the actual dossier of each enterprise.
💡 Enterprises should proactively review their dossiers early to mitigate tax risks and avoid prolonged
VAT refund processing.
📩 Contact MBA for advice and support tailored to your enterprise’s actual situation.
📌 Note: This article is intended for general information purposes only. Its application should be assessed
based on the actual dossiers and transactions of each enterprise.
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