| MINISTRY OF FINANCE OF VIETNAM | SOCIALIST REPUBLIC OF VIETNAM |
| No. 4994/TCT-CS | Hanoi, November 08, 2023 |
To:
- Departments of Taxation of provinces and centrally affiliated cities;
- Major Enterprise Department of Taxation
Reagarding the impacts of global minimum tax on corporations having ultimate parent entities (UPEs) in Vietnam, General Department of Taxation has issued and sent Official Dispatch No. 1939/TCT-CS dated 19/5/2023 to Departments of Taxation of provinces and centrally affiliated cities and Major Enterprise Department of Taxation.
In order to ensure the adequacy of data reported to the Ministry of Finance, the Government and the National Assembly of Vietnam, Departments of Taxation need to continue examining the eligibility of corporations having UPEs in Vietnam for application of global minimum tax, and directly work with enterprises to complete the report according to the Global Minimum Tax Impact Assessment Sheet in the Appendix enclosed herewith.
In case any of the 64 corporations on the List enclosed with Official Dispatch No. 1939/TCT-CS dated 19/5/2023 is found to be ineligible for application of global minimum tax, the Departments of Taxation must report and provide explanation.
General Department of Taxation attaches a Draft Resolution on application of top-up tax according to regulations on global anti-base erosion (planned to be effective from the fiscal year of 2024) and the Open Letter about application of the Resolution.
Departments of Taxation shall send the Open Letter to corporations and enterprises under their management which are potentially regulated by the Resolution for dissemination purpose, and cooperate with enterprises in assessing the impacts of regulations on global minimum tax as well as preparing for the entry into force of the Resolution.
Reports shall be sent both in writing to General Department of Taxation at 123 Lo Duc street, Hai Ba Trung district, Hanoi and by email to [email protected] before 16/11/2023.
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PP GENERAL DIRECTOR
DEPUTY GENERAL DIRECTOR
Dang Ngoc Minh
GLOBAL MINIMUM TAX IMPACT ASSESSMENT SHEET
(Applicable to multinational corporations having ultimate parent entities in Vietnam)
PART I. GENERAL INFORMATION
1. Name of multinational corporation:
2. Tax period: from ........... to ..........
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4. TIN of the UPE:
5. Revenue on consolidated financial statements of the UPE:
- 2019:
- 2020:
- 2021:
- 2022:
PART 2. IMPACT ASSESSMENT
(Unit: million VND)
No.
...
...
...
Name of constituent entity (CE)
Pre-tax income on 2022's financial statements of the CEs
Total pre-tax income on 2022's financial statement s of the CEs in each country
Total income or loss in 2022 of the corporation in each country
Total tax payable in 2022 of the corporation in each country
Average revenue of the corporation in each country
Average income or loss of the corporation in each country
Exeptions due to low revenue and income
Actual tax rate of the corporation in each country
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...
Total salaries according to 2022's financial statements of the CEs in each country
Total value of tangible assets (after depreciation) according to 2022's financial statements of the CEs in each country
Value of tangible assets and deductible salaries
Profit subject to top-up tax
Total top-up tax in a country
Top-up tax of each CE
Ratio of distribution to UPE by CEs
Top-up tax distributed to UPE
(6)
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(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)= (12)/ (11)
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(18)
(19)
(20)= 10%*(18) +8%*(19)
(21)=(11) -(20)
(22)=(21)* (17)
(23)=(22)*(9) /(10)
(24)
(25)=(23)* (24)
1
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A
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B
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C
2
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D
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E
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F
3
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G
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H
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I
(7) Arrange by country in which the entities affiliated to the corporation invest.
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(11) Total income or loss in 2022 of the corporation in each country = income in 2022 of all profitable CEs in a country – Loss in 2022 of all loss-making CEs in the same country.
(13) Average revenue of the corporation in each country – average revenue of 3 years ((2020, 2021, 2022) in the same country.
Where: revenue in a country is the total revenue of the CEs in such country.
(14) Average income or loss of the corporation in each country = Average income or loss of 3 years (2020, 2021,2022) in the same country.
Where: Income or loss in a country is the total income or loss of the CEs in such country.
(15) Top-up tax in a country is 0 if the corporation satisfies both conditions below:
- The average revenue is under 260 billion VND (equivalent to 10 million Euro)
- The average pre-tax income is under 26 billion VND (equivalent to 1 million Euro)
(22) Top-up tax of CEs shall be determined for every CE that generates income in the fiscal year.
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File gốc của Official Dispatch No. 4994/TCT-CS dated November 08, 2023 on Assessment of impacts of global minimum tax đang được cập nhật.
Official Dispatch No. 4994/TCT-CS dated November 08, 2023 on Assessment of impacts of global minimum tax
Tóm tắt
| Cơ quan ban hành | Tổng cục Thuế |
| Số hiệu | 4994/TCT-CS |
| Loại văn bản | Công văn |
| Người ký | Đặng Ngọc Minh |
| Ngày ban hành | 2023-11-08 |
| Ngày hiệu lực | 2023-11-08 |
| Lĩnh vực | Thuế - Phí - Lệ Phí |
| Tình trạng | Còn hiệu lực |