Công văn 2932/TCT-CS

To: Hai Phong City Tax Office
Khanh Hoa Province Tax Office

The General Department of Taxation has received a number of official letters inquiring about value-added tax policies for goods and services directly supplied for vehicles (for international transport activities) owned by Vietnamese organizations and individuals. Regarding this issue, the General Department of Taxation gives the following opinions:

Point 1.23.d.2, Section II, Part A of the Finance Ministry's Circular No. 32/2007/TT-BTC of April 9, 2007, guiding the value-added tax, stipulates: “Goods and services supplied to assure the operation of vehicles engaged in international transportation such as petrol and oil, and vehicle repair, painting and maintenance and some other goods and services supplied to assure the operation of vehicles, excluding registry, insurance, repair, painting and maintenance services directly provided for vehicles owned by Vietnamese organizations and individuals or vehicles bareboat- chartered or time-chartered by Vietnamese organizations and individuals from foreign organizations and individuals, which are all subject to value-added tax as guided in Part B of this Circular.

Vehicles mentioned at Point 1.23.d2 include:

+ Vehicles engaged in international transportation owned by organizations and individuals overseas.

+ Vehicles owned by Vietnamese organizations and individuals or those bareboat- chartered or time-chartered by Vietnamese organizations and individuals from foreign organizations and individuals for international transportation.”

Under the above guidance, except registry, insurance, repair, painting and maintenance services directly provided for vehicles (for international transportation activities) owned by Vietnamese organizations and individuals or those bareboat- chartered or time-chartered by Vietnamese organizations and individuals from foreign organizations and individuals, which are subject to value-added tax as guided in Part B of this Circular, other goods and services supplied to assure the operation of vehicles (for international transportation activities) owned by Vietnamese organizations and individuals or those bareboat-chartered or time-chartered by Vietnamese organizations and individuals from foreign organizations and individuals are not subject to VAT.

The General Department of Taxation informs the Provincial Tax Offices thereof for information.