No 30% CIT reduction this year without 2019 revenue

Companies that generated no revenue in 2019 will not be eligible for a 30% reduction in corporate income tax for 2021 since there is no benchmark to determine revenue decline in the year, according to tax authorities.

Photo courtesy of TMF Group, a multinational professional services firm in the Netherlands.

Our company was established in August 2019 and did not generate revenue in that first year of operation. In 2021, we generated a revenue of VND190 billion ($8.13 million). Could we apply a 30% CIT reduction for 2021 in line with Decree 92/2021/ND-CP?

In accordance with the provision of Decree 92/2021/ND-CP, enterprises with revenue not exceeding VND200 billion in 2021 and a decrease in revenue compared to 2019 will be eligible for a 30% CIT reduction in 2021.

Recently, the General Department of Taxation (GDT) further clarified that 30% CIT reduction for 2021 will not be available if taxpayers have no revenue generated in 2019 (i.e. there is no benchmark to determine revenue decrease for 2021).

We understand that tax authorities will not sell paper-based PIT withholding certificates from July 1, 2022. Instead, taxpayers need to use e-certificates in accordance with the provision of Decree 123/2020/ND-CP. Do we have to destroy all remaining paper-based PIT withholding certificates and report to tax authorities from July 1, 2022?

In accordance with the provision of Decree 123/2020/ND-CP, tax authorities will no longer sell paper-based PIT withholding certificates. Instead, taxpayers could create e-certificates with their own software in line with Decree 123.

During the transitional period where the e-certificate is not available, taxpayers can create the certificate on their own. Residual certificates purchased from tax authorities could still be used after July 1, 2022.

Our company holds export revenue from overseas goods sales though sometimes our monthly revenue derives fully from domestic sales. Can we apply a VAT refund for the month without export sales?

Under current regulations, taxpayers holding export revenues could claim an input VAT refund not exceeding 10% of export sales. In case your company has no export sales in certain months, input VAT incurred in these month will not eligible for a VAT refund. 

* Please email Vn-fmntg@kpmg.com.vn if you have questions on tax issues.