Tax policy of EPE

when performing the processing contract

General Department of Customs (GDC) has issued the official letter No. 5589-TCHQ-TXNK dated on August 21st, 2020 about guiding policy tax of EPE when per--forming the processing contract.

According to this official letter, tax policy of EPE and their partners will be applied as below:

1. When EPE receives outsourcing for other EPE:

- For Import tax, export tax: goods under processing contract between EPEs shall be

  exempted from import and export taxes.

- For VAT of processing service of EPE providing to other EPE: EPE receiving

   outsourcing for other EPE will be considered as trading goods, services between

   non tariff zones, so that this kind of transaction are not subject to VAT tax

   according to Clause 20, Article 4, Circular 219/2013/TT-BTC.

“Article 4. Goods and services that are not subject to VAT

… 20. The goods forwarded through Vietnam’s territory; goods temporarily

imported or temporarily exported, raw materials imported for manufacturing or

export processing under contracts with foreign partners. The goods and services

traded between a foreign party and a free trade zone, or among free trade zones.”

2. When EPE receives outsourcing for domestic company

a) With domestic company:

 - For import tax: must be paid when they receive processed products from EPE

   base on Clause 8, Article 16, Law on Import and Export duties No. 107/2016/QH1 

   3. Taxable amount are processing fee according to Clause 3, Article 17, Circular 39   

   /2015/TT-BTC, specially the value of which materials/ supplies domestic company

   sent to EPE under processing contract shall not be included in the customs value.

 - For VAT tax: domestic company must declare and pay VAT tax base on taxable

   amount as Clause 2, Article 7, Circular 219/2013/TT-BTC.

b) With EPE company:

    - VAT of processing fee: EPE must pay VAT 10%  according to Clause 7, Article 30,       

      Decree 82/2018/NĐ-CP dated on 22/5/2018.

“Export processing enterprises, when being permitted to purchase, sell goods and

carry out other activities directly related to the purchase and sale of goods in

Vietnam, must open separate accounting books for revenue and expenses related to these activities in Vietnam, arranging zones for storage of goods for such purchase or sale separated from those for production activities of export-processing

enterprises, or setting up separate branches outside export processing enterprises or export processing zones to carry out these activities.”

베트남의 EPE가 아웃소싱을 받는 경우 관부가세 정책

베트남 EPE 아웃소싱 관세 부가세