Leasing income not qualified for CIT incentive entitlement

By KPMG
Mon, December 12, 2022 | 3:39 pm GMT+7

1. Our company has a 12-month deposit at Vietcombank (VCB), which will be for the period from March 2022 to February 2023. As per the deposit agreement, VCB would pay us both deposit amount and interest by the maturity date (i.e. by the end of February 2023). By December 31, 2022, do we have to accrue the interest income from the deposit agreement and pay CIT?

In accordance with current CIT regulations, a taxpayer is not required to accrue interest income in such case. Thus, the company is only required to recognize the interest income for CIT calculation purposes upon your actual receipt of the interest income by the deposit maturity date (i.e. end of February 2023).

Photo courtesy of KPMG.

Photo courtesy of KPMG.

2. Our company was established in Bac Can province with a granted IRC to implement a pig farm. However, due to a change in our business model, we decided not to proceed with the project. Instead, we rent the farm to another company to earn the leasing income. Could we enjoy the CIT incentive for such leasing income?

As the company was located in a difficult socio-economic area (i.e. incentivized location), all income derived by the company in that incentivized location should be qualified to enjoy the CIT incentive, provided that the leasing activity was registered under your initial IRC. As the leasing activity was not included into the original IRC, it is likely that the leasing income is not qualified for CIT incentive entitlement.

3. We are a manufacturing company whose products are mostly for exportation to overseas buyers. In September 2022, we applied a VAT refund and got refunded for the period from January 2022 to July 2022 based on export revenue. In October 2022, one of our clients overseas informed us that our goods exported in July 2022 was not qualified and thus we need to recall such exported goods. Do we need to take any action related to the refunded VAT amount?

According to the current guidance from tax authorities, as the export revenue of the VAT refunded period has been decreasingly adjusted, the company needs to adjust its VAT declaration for July 2022. Subsequently, if the amended VAT declaration in July 2022 results into a decrease of refunded VAT, the company needs to repay the over-refunded VAT plus interest on late payment to tax authorities.

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