1. According to Decree No. 123/2020/ND-CP, the timing of e-invoice issuance shall be (i) upon the transfer of goods ownership/right to use goods to the buyer, or (ii) upon the completion of customs clearance if the taxpayers declare VAT under the credit method. Our company is an export processing enterprise (EPE) hence we are not a VAT taxpayer. Which is the timing of e-invoice issuance when export good?
The Ministry of Finance recently confirmed under the Official Letter No. 8404/BTC-CS dated August 23, 2022 that an EPE needs to issue e-sale invoices upon the transfer of ownership of goods. Official Letter 8404 was copied to all provincial tax departments for consistent implementation.
2. Our commercial bank incurs a huge number of foreign exchange transactions every day. We have implemented e-invoice as stipulated by Decree 123/2020/ND-CP. Is it possible if we issue a consolidated invoice with a detailed attachment of all foreign exchange transactions conducted in the day or month?
According to current regulations, commercial banks can issue invoices on monthly basis to corporate customers if such invoicing arrangement is contractually agreed by the parties. In case of transacting with individual customers who do have the demand to collect the invoices, the bank can issue a lump-sum invoice at the end of the day for those transactions.
3. Our enterprise was established in 2008 to operate a new investment project of producing electronic components located in a difficult socio-economic condition area. Until 2021, we fully enjoyed CIT incentives that apply to our project (i.e. preferential CIT rate of 15% within 12 years, tax exemption for three years, reduction of 50% of tax payable for the following seven years). In 2022, we obtained a certificate of incentives for production of supporting industry products granted by the Ministry of Industry and Trade for the same project. What is the CIT incentive package we can enjoy under the conditions of supporting industry products manufacturing projects?
According to Decree 57/2021/ND-CP, in case meeting all regulations, the company can apply for CIT incentives for supporting industry products and manufacturing projects for the remaining period from the year 2022, specifically: preferential CIT rate of 10% within three years, CIT exemption for one year, 50% reduction of tax payable for the following two years.
* Please email Vn-fmntg@kpmg.com.vn if you have questions on tax issues.