Circular No. 07/2007/TT-BTC guiding financial regulations and customs procedures applicable at the Vung Ang Economic Zone, Ha Tinh Province

CIRCULAR

Decision No. 07/2007/TT-BTC of the Ministry of Finance guiding financial regimes and customs procedures applicable at the Vung Ang Economic Zone, Ha Tinh Province.

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Pursuant to the State Budget Law;

Pursuant to laws and ordinances on taxes, fees, and charges;

Pursuant to Decision No. 72/2006/QĐ-TTg dated April 3, 2006 of the Prime Minister on the establishment and issuance of regulations for the operation of the Vung Ang Economic Zone, Ha Tinh Province;

The Ministry of Finance guides the financial regime and customs procedures applicable at the Vung Ang Economic Zone as follows.

This technical regulation sets out technical requirements, testing methods, sampling procedures; management requirements; responsibilities of organizations and individuals producing, trading, and importing cigarettes.

Article 1. Scope of Application:

The financial regime and customs procedures stipulated in this Circular (hereinafter referred to as the financial regime) shall be applied within the territory of the Vung Ang Economic Zone, Ha Tinh Province (hereinafter referred to as the Vung Ang Economic Zone).

The financial regime stipulated in this Circular shall only apply to business activities conducted within the territory of the Vung Ang Economic Zone. In cases where organizations and individuals conduct business activities both within the Vung Ang Economic Zone and within the domestic territory of Vietnam, they must separately account for their business activities within the Vung Ang Economic Zone as the basis for determining the applicable financial regime.

Foreign-invested enterprises and foreign parties participating in joint venture contracts that have been granted investment licenses; domestic business establishments that have been granted Investment Preference Certificates at the Vung Ang Economic Zone before the effective date of Decision No. 72/2006/QĐ-TTg dated April 3, 2006 of the Prime Minister (hereinafter referred to as Decision No. 72/2006/QĐ-TTg), but have not yet fully enjoyed preferential policies, shall enjoy the preferential policies prescribed in this Circular for the remaining period of preferential treatment. In cases where projects have higher preferential levels than those prescribed in this Circular, such preferential treatments shall continue to be implemented according to the Investment License for the remaining duration of the project.

第二条 组织和实施奖励工作的支出水平，如政府第152/2025/NĐ-CP号决定关于分级授权和奖励领域的分权规定

The objects subject to this Circular are investors belonging to various economic sectors operating in accordance with the Investment Law, Enterprise Law, Cooperative Law, individual business households, and independent practitioners, as well as organizations and individuals engaged in business activities in accordance with Vietnamese law.

3. Definitions:

In this Circular, the following terms are understood as follows:

- Non-Tariff Zone: is a geographic area separated from other functional zones of the Vung Ang Economic Zone by a physical barrier as provided for in Articles 7 and 8 of the Regulations for the Operation of the Vung Ang Economic Zone issued together with Decision No. 72/2006/QĐ-TTg.

- Functional Zones: include industrial zones, port and post-port service zones, tourism and entertainment zones, urban zones, residential zones, and administrative zones (excluding export processing zones) identified in the General Master Plan of the Vung Ang Economic Zone approved by the Prime Minister.

- Domestic Territory of Vietnam: includes the functional zones within the Vung Ang Economic Zone and the remainder of the territory of Vietnam (excluding non-tariff zones defined in Clause 1, Article 5 of the Export Tax, Import Tax Law 2005, and Clause 2, Article 1 of Decree No. 149/2005/NĐ-CP dated December 8, 2005, hereinafter referred to as other non-tariff zones).

- Customs Control Gate: The non-tariff zone has two customs control gates: the customs control gate located at the boundary between the non-tariff port and the sea, abbreviated as Gate A; the customs control gate located at the boundary between the non-tariff port and the domestic territory, abbreviated as Gate B.

- List of Goods Originating from the Non-Tariff Zone: Is a list of goods issued periodically by the Management Board of the Vung Ang Economic Zone (hereinafter referred to as the Management Board) (referred to as the List of Goods Originating from the Non-Tariff Zone) comprising goods produced, processed, recycled, or assembled in the Non-Tariff Zone without using imported raw materials or components from abroad.

4. Conditions for Applying Financial Regimes Related to the Non-Tariff Zone:

The financial mechanisms prescribed for the Non-Tariff Zone within the Vung Ang Economic Zone shall only be applicable when the Non-Tariff Zone satisfies the following conditions simultaneously:

- There is a physical barrier ensuring isolation of activities within the Non-Tariff Zone from other functional zones within the Vung Ang Economic Zone;

- Within the Non-Tariff Zone, there are no residential areas, nor permanent or temporary residents (including foreigners);

- There is a customs authority supervising and inspecting people, goods, and means of transport entering and exiting the Non-Tariff Zone.

5. Some General Provisions on Customs Procedures for the Non-Tariff Zone:

a) Organizations and individuals operating within the Non-Tariff Zone may export to and import from abroad all goods and services not prohibited by Vietnamese law. Policies on export and import items are implemented according to the Prime Minister's regulations on managing exports and imports of goods during each period and the implementing guidelines of relevant ministries and agencies. The export and import of goods listed in the conditional export-import list and restricted trade goods shall be carried out in accordance with the guidance of the Ministry of Commerce.

b) Every six months, enterprises within the Non-Tariff Zone are responsible for submitting to the customs authority a report on the settlement of materials, raw materials, exported and imported goods in the period, and a report on production inventory. The customs authority will check and compare these reports and send them to the tax authority for verification and determination of taxes payable.

c) Goods, luggage for export, import, transit; means of transport for departure, entry, and transit through the Non-Tariff Zone, regardless of the type, shall follow the customs procedures specified for that type.

d) Goods for export, import, transit; means of transport for departure, entry, and transit through the Non-Tariff Zone can only pass through Gate A and Gate B.

đ) Goods from abroad passing through Gate B, goods from the domestic territory exported into the Non-Tariff Zone and vice versa, shall handle customs formalities at Gate B; goods from abroad entering the Non-Tariff Zone and goods from the Non-Tariff Zone exported to abroad through Gate A shall handle customs formalities at Gate A.

e) Goods from the domestic territory exported to abroad through Gate A or goods from abroad passing through Gate A into the domestic territory shall handle customs formalities according to current regulations at Gate A or at a customs office outside the border gate. If handled at a customs office outside the border gate, customs procedures shall be carried out according to the regulations on goods transferred to another border gate.

f) In addition to the customs procedures specified above, the relevant parties must comply with other obligations prescribed in the Law on Customs, the Law on Export Duties, Import Duties, and other documents related to export and import activities.

6. Investment incentives principle:

Investment projects in the Vung Ang Economic Zone shall enjoy the maximum incentives provided for investment projects in areas with particularly difficult socio-economic conditions as stipulated in the Investment Law, the Law on Corporate Income Tax, the Law on Value Added Tax, and other incentives under international treaties, bilateral and multilateral trade agreements to which Vietnam is a party.

Where different legal regulations provide different levels of incentives for the same issue, the higher-ranking legal document's provisions shall apply.

Where different legal regulations issued by the same authority provide different provisions on the same issue, the later-issued regulation shall apply.

II. SPECIFIC PROVISIONS

1. Tax policy for the Vung Ang Economic Zone:

1.1. Corporate Income Tax:

a) Domestic and foreign organizations and individuals investing in new production and business establishments within the Vung Ang Economic Zone shall be subject to a corporate income tax rate of 10% for 15 years from the date the project commences operations; they shall be exempted from corporate income tax for four years from the date taxable income is generated; and their tax liability shall be reduced by 50% for the next nine years.

b) Domestic and foreign organizations and individuals investing in high-tech fields within the Vung Ang Economic Zone that meet the criteria set forth in Clause 2, Article 5 of Decree No. 99/2003/NĐ-CP dated August 28, 2003 of the Government on the establishment of High-Tech Zones shall be subject to a corporate income tax rate of 10% throughout the duration of the project.

c) Production and business establishments investing in new production lines, expanding scale, updating technology, improving ecological environment, and enhancing production capacity shall follow current laws.

d) Income from land use rights transfer and land lease rights transfer shall be taxed according to the guidelines set out in Section C of Circular No. 128/2003/TT-BTC dated December 22, 2003 of the Ministry of Finance guiding the implementation of Decree No. 164/2003/NĐ-CP dated December 22, 2003 of the Government detailing the implementation of the Law on Corporate Income Tax.

đ) To benefit from corporate income tax incentives, domestic and foreign organizations and individuals with investment projects in the Vung Ang Economic Zone must submit copies of their Business Registration Certificate (for domestic enterprises) or Investment License (for foreign-invested enterprises) to the tax authority where the enterprise declares and pays taxes. The corporate income tax incentive applies only to production and business establishments that fully comply with accounting records, invoices, and certificates registered and declared for tax purposes.

e) During operation, if a company incurs losses after settling taxes with the tax authority, it may carry forward the loss to offset against future taxable income. The carry-forward period shall not exceed five years.

f) Companies are responsible for notifying the tax authority where they declare and pay taxes about the period during which they are exempted or granted reductions in corporate income tax as stipulated herein.

1.2. Income Tax for High-Income Individuals:

Workers (including both Vietnamese and foreigners) working in the Vung Ang Economic Zone shall have their income tax reduced by 50% for income earned from work in the Vung Ang Economic Zone, including both regular and irregular income.

The declaration, payment, and settlement of income tax shall be carried out in accordance with current legal documents guiding the taxation of high-income individuals.

1.3. Export Duties and Import Duties:

a) Goods exported or imported in the following cases are not subject to export duties or import duties:

- Goods from non-tariff zones exported abroad; Goods from abroad imported into non-tariff zones and solely used within non-tariff zones;

- Goods transferred from or sold between non-tariff zones.

- Other goods not subject to export duties originating from Vietnam brought into non-tariff zones.

b) Goods subject to export duties originating from Vietnam and brought into non-tariff zones must pay export duties and go through export procedures as prescribed.

c) Goods from non-tariff zones imported into Vietnam must pay import duties as follows:

- Goods from abroad must pay import duties according to current regulations.

- Goods produced, processed, recycled, or assembled in non-tariff zones may be subject to preferential ASEAN Import Tariff Rates (CEPT) if they meet the current requirements.

- Goods listed in the non-tariff zone origin list imported into Vietnam are exempt from import duties.

- Goods produced, processed, recycled, or assembled in non-tariff zones within the Vung Ang Economic Zone using imported raw materials and components directly from abroad (excluding goods imported from Vietnam using imported raw materials and components from abroad) when imported into Vietnam only need to pay import duties on the imported raw materials and components constituting the goods.

The basis for determining the import duty payable on imported raw materials and components constituting goods imported into Vietnam is:

The tax value determined according to current regulations; the quantity of goods imported into Vietnam; the import duty rate applicable to each type of raw material and component. The tax value and duty rate are applied at the time of declaring importation into Vietnam. Organizations and individuals engaged in production and business must register with the Customs Authority regarding the list of imported goods used as raw materials for production and the quota of raw materials and components used to produce imported goods before importing them into Vietnam.

The value of imported raw materials and components constituting each unit of goods imported into the domestic market shall be determined in accordance with the regulations on the customs value for import tax applicable to imported goods at the time of importation into the domestic market of Vietnam.

d) Investment projects for production within the Vung Ang Economic Zone by domestic and foreign organizations and individuals shall be exempt from import tax on raw materials for production, spare parts, components, and semi-finished products that have not yet been produced domestically for five years, starting from the date of commencement of production.

The procedures, documents for tax exemption, declaration, and settlement of import tax in this case shall be carried out in accordance with the Law on Export Tax and Import Tax; Decree No. 149/2005/NĐ-CP dated December 8, 2005, and Circular No. 113/2005/TT-BTC dated December 15, 2005 of the Ministry of Finance guiding the implementation of export tax and import tax.

đ) Domestic and foreign organizations and individuals engaged in production and business activities in the Duty-Free Zone importing raw materials for production, spare parts, goods from abroad but not fully utilized, and by-products still having commercial value are permitted to sell them into the domestic market of Vietnam after completing customs formalities and paying import tax according to current regulations.

1.4. Special Consumption Tax:

a) Goods and services subject to special consumption tax produced and consumed in the Duty-Free Zone or imported from abroad into the Duty-Free Zone and vice versa are exempt from special consumption tax. However, passenger cars with less than 24 seats must pay special consumption tax according to the general current regulations.

b) Goods and services subject to special consumption tax exported from the domestic market of Vietnam into the Duty-Free Zone are exempt from special consumption tax. However, passenger cars with less than 24 seats must pay special consumption tax according to the general current regulations.

c) Goods and services subject to special consumption tax transferred from or sold between duty-free zones are exempt from special consumption tax.

d) Goods subject to special consumption tax imported from the Duty-Free Zone into the domestic market of Vietnam must pay special consumption tax on imported goods according to current regulations.

1.5. Value Added Tax:

Enterprises in the Vung Ang Economic Zone may use value-added tax invoices in accordance with current regulations, and shall register, declare, and pay value-added tax in cases where they are required to pay value-added tax as stipulated in this Circular. For cases where goods are not subject to value-added tax, the value-added tax line in the value-added tax invoice shall be crossed out (x). Specifically, as follows:

a) Goods and services produced and consumed in the Duty-Free Zone and imported from abroad into the Duty-Free Zone and vice versa are exempt from value-added tax.

b) Goods and services transferred from or sold between duty-free zones are exempt from value-added tax.

c) Goods and services exported from the domestic market of Vietnam into the Duty-Free Zone enjoy a zero percent value-added tax rate.

d) Goods and services imported from the Duty-Free Zone into the domestic market of Vietnam must pay value-added tax on imported goods at the rates specified in current regulations. Specifically, enterprises in the Duty-Free Zone when selling to domestic enterprises, organizations, or individuals shall issue invoices without value-added tax, crossing out the tax rate and value-added tax lines. Domestic enterprises, organizations, or individuals (or enterprises in the Duty-Free Zone in the Vung Ang Economic Zone in cases where they bring goods into the domestic market for sale themselves) only need to pay value-added tax on imported goods based on the customs declaration when completing import procedures into the domestic market.

1.6. Regarding prices, fees, and other taxes:

a) Land rental prices, land lease prices for land with built-in technical infrastructure structures, and usage fees for technical infrastructure structures, service facilities, and public utilities in the Vung Ang Economic Zone shall be determined by infrastructure business enterprises after negotiating with the Management Board of the Vung Ang Economic Zone.

b) Other types of taxes, fees, and charges shall be implemented in accordance with current laws, ordinances, and guiding legal documents on taxes, fees, and charges, the Investment Law, and other relevant legal documents.

2. Customs Procedures for Goods Entering and Leaving the Duty-Free Zone:

2.1. For goods imported from abroad into the Duty-Free Zone:

a) Imported through Gate A:

- Organizations and individuals engaged in production and business importing goods are responsible for declaring customs, submitting customs documents in accordance with current regulations for each type of import as stipulated in Clause 5, Section I of this Circular.

- The customs authority at Gate A shall handle necessary procedures in accordance with current regulations for each type of goods.

b) Imported through Gate B: Follow current regulations regarding transshipment imports.

2.2. For goods imported from abroad into the domestic market of Vietnam through Gate A and goods exported from the domestic market to abroad through Gate A: Follow current regulations.

2.3. For goods exported from the domestic market to the Duty-Free Zone:

a) In cases where organizations and individuals engaged in production and business in the domestic market register customs procedures with the customs authority at Gate B, they are responsible for declaring customs and submitting customs documents in accordance with regulations for each type of export. In cases of internal transportation of goods between enterprises and branches within and outside the Duty-Free Zone, sales contracts can be replaced by warehouse release documents. The customs authority at Gate B is responsible for implementing full export procedures for organizations and individuals engaged in production and business in the domestic market in accordance with regulations for each type of export.

b) In cases where organizations and individuals engaged in production and business in the domestic market declare export declarations at the domestic customs office branch: Customs procedures shall be carried out in accordance with current regulations for transshipment exports. The customs authority at Gate B shall perform the duties of the export customs office for transshipment exports (except for confirming actual export).

2.4. For goods exported from the Free Zone to foreign countries:

a) Through Gate B: Implement according to the current regulations for export goods transiting through border gates.

b) Through Gate A: Register to handle customs procedures at the Gate A Customs Office. The Gate A Customs Office shall implement customs procedures according to the current regulations for export goods.

2.5. For goods brought into the domestic market from the Free Zone:

a) Goods listed in the Catalogue of goods originating from the Free Zone that are exempted from customs procedures but must be declared regarding quantity to the Customs Office and subject to supervision by the Customs Office.

b) Other goods must fully complete customs procedures as follows:

- Organizations and individuals engaged in production and business activities within the Free Zone (seller) have the responsibility to provide organizations and individuals engaged in production and business activities within the domestic market (buyer) with all necessary certificates, invoices, and documents as prescribed by the Customs Office so that domestic enterprises can declare customs and submit customs documents in accordance with the regulations applicable to each type of import at the Gate B Customs Office.

- The Gate B Customs Office has the responsibility to handle customs procedures for imported goods of domestic enterprises in accordance with the regulations. In case it is found that foreign goods are brought into the Free Zone to continue being imported into the domestic market under the same category as goods listed in the Catalogue of goods originating from the Free Zone announced by the Management Board of Vung Ang EPZ, but the enterprise does not declare customs, then the Gate B Customs Office shall request the presentation of documents proving the origin of the consignment; proceed to handle violations and process the importation of the consignment in accordance with the law; and simultaneously notify the Management Board of Vung Ang EPZ to take management measures or remove the goods from the Catalogue of goods originating from the Free Zone.

2.6. For processed goods:

Customs procedures for goods processed by organizations and individuals engaged in production and business activities within the Free Zone for foreign traders or hiring organizations and individuals engaged in production and business activities within the domestic market to process and vice versa shall be implemented according to the current regulations.

2.7. Temporary export-reimport; temporary import-reexport; transfer; transit and transportation:

Exported, imported, transited goods, vehicles exiting, entering, transiting and transporting through the Free Zone may only pass through gates equipped with customs checkpoints. Customs procedures for temporary export-reimport; temporary import-reexport; transfer; transit and transportation within the Free Zone shall be carried out according to the current regulations.

2.8. In addition to the guidelines set forth in this Circular, enterprises must comply with other obligations stipulated in the Law on Customs, the Law on Export Duties and Import Duties, and other guiding documents on customs.

3. Development Incentives for Infrastructure

3.1. Investment Support from the State Budget for Infrastructure Construction:

a) Scope and Object of Investment from the State Budget (SB):

- The State budget supports investment in constructing technical-social infrastructure projects and important public service and utility projects serving the entire Vung Ang EPZ according to programs and targets approved by competent authorities in the approved budget. The SB only supports investment in common infrastructure projects for the entire Vung Ang EPZ, excluding infrastructure dedicated to individual functional zones within the Vung Ang EPZ.

- Investment support from the SB for constructing infrastructure in the Vung Ang EPZ shall be carried out strictly in accordance with approved projects consistent with the planning approved by competent authorities.

- The Management Board of the Vung Ang EPZ is the local planning focal point responsible for balancing basic construction funds from the SB to construct infrastructure in the Vung Ang EPZ; directly managing investment construction projects funded by the SB within the Vung Ang EPZ in accordance with current state regulations on investment construction management.

b) Investment Support from the SB for Infrastructure Construction:

- Annually, based on economic-social infrastructure investment projects already approved by competent authorities, project implementation progress, the central budget supplements targeted funds to the Ha Tinh provincial budget to invest in the structural infrastructure of the Vung Ang EPZ in accordance with the State Budget Law.

- Central budget support funds targeted for the Ha Tinh provincial budget to invest in economic-social infrastructure projects, public service and utility projects of the Vung Ang EPZ are clearly allocated in the annual SB allocation plan for Ha Tinh Province. Along with central budget support, Ha Tinh Province annually allocates its local budget to invest in economic-social infrastructure, public service and utility projects of the Vung Ang EPZ in accordance with point a of this clause.

c) Revenue generated on the territory shall be paid into the state budget. The division of revenue sources between the central budget and the local budget shall be in accordance with current laws.

d) Management and Use of Funds Supported by the State Budget for Infrastructure Construction:

Funds supported by the state budget for infrastructure construction in the Vung Ang EPZ shall be managed and used in accordance with regulations on basic construction investment management, the State Budget Law, and current guiding documents. The preparation of budgets shall be carried out in accordance with the State Budget Law.

3.2. Mechanism for Using Land Funds to Generate Capital for Infrastructure Development:

The Management Board is assigned annual targets and is the direct investor managing projects using land funds in the Vung Ang EPZ; organizing bidding to select units with sufficient financial capacity, experience, and reputation to carry out construction of infrastructure projects funded by land funds in the Vung Ang EPZ.

The Management Board compiles a list of infrastructure construction projects using land funds to generate capital and the area of land used to generate capital for project implementation, which is sent to the Department of Finance and the Department of Planning and Investment for consolidation in accordance with the State Budget Law to be submitted to the People's Committee of Ha Tinh Province for approval by the People's Council of Ha Tinh Province or decided within their authority.

Pursuant to the land use planning of the locality, the ability to collect land use fees, land lease fees from auctions, revenues from land use and leasing without auctions, and the needs for compensation and support for individuals whose land has been expropriated, as well as the investment needs for infrastructure projects funded from the state budget according to the provisions of the law, the People's Committee of Ha Tinh Province directs the financial agency to consolidate these revenue and expenditure tasks into the annual state budget estimate to be submitted to the same-level People's Council for decision.

Based on the annual state budget estimate decided by the People's Council, the People's Committee assigns the financial agency to coordinate with relevant units to organize the collection and disbursement from the sources of land use fees and land lease fees, and settle accounts into the state budget according to the prescribed regulations.

In cases where organizations or individuals advance funds to implement compensation and support for individuals whose land has been expropriated for the purpose of investing in infrastructure projects funded from the state budget, followed by conducting auctions to collect land use fees and lease fees, the land use and lease fee revenues used to repay the organizations and individuals who advanced the funds must be fully recorded as income and expenditure in the state budget according to current laws.

The use of land funds to build infrastructure in the Vung Ang Special Economic Zone shall be carried out in accordance with Decree No. 181/2004/ND-CP dated October 29, 2004 of the Government on implementing the Land Law, Decree No. 17/2006/ND-CP dated January 27, 2006 of the Government amending and supplementing certain articles of decrees guiding the implementation of the Land Law, Decision No. 216/2005/QD-TTg dated August 31, 2005 of the Prime Minister on promulgating the auction rules for land use rights to grant land with land use fees or lease land, and other relevant current legal provisions.

3.3. Investment in infrastructure from ODA funds and other sources:

Infrastructure technical-social works, public utility service works necessary for the Vung Ang Special Economic Zone and other technical aids shall be prioritized for inclusion in the list of ODA funding calls and may use other forms of capital mobilization according to Article 21 of the Operation Regulations of the Vung Ang Special Economic Zone issued together with Decision No. 72/2006/QD-TTg dated April 3, 2006 of the Prime Minister.

4. Financial regime applicable to the Management Board of the Vung Ang Special Economic Zone:

4.1. The Management Board is a local state budget unit. The operating expenses of the Board are guaranteed by the local state budget. All revenues collected according to the regulations implemented by the Management Board must be deposited into the state budget as prescribed.

4.2. The Management Board is permitted to collect various fees and charges corresponding to the tasks delegated by state management agencies according to current regulations. When authorized by competent state authorities to perform revenue collection tasks, the Management Board is responsible for notifying and registering with the tax authority where the Management Board is located to complete procedures for depositing the collected fees and charges due to the performance of delegated tasks.

III. IMPLEMENTATION

1. The People's Committee of Ha Tinh Province is responsible for ensuring that all conditions stipulated in Clause 4, Section I are met so that the Tax-Free Zone can apply the financial regime prescribed in this Circular. If the conditions are not met, it cannot be applied.

2. The General Department of Customs is responsible for:

Based on the customs procedures stipulated in this Circular and the existing customs procedures applicable in the Tax-Free Zone, to specify detailed customs procedures applicable in the Tax-Free Zone within the Vung Ang Special Economic Zone.

3. The Ha Tinh Provincial Customs Office is responsible for:

- Organizing anti-smuggling, commercial fraud work, preventing illegal importation of goods from the Tax-Free Zone into Vietnam's mainland and at other areas within its customs jurisdiction.

- Cooperating with the Management Board of the Special Economic Zone and related agencies (Tax, Police, Border Guard) to carry out anti-smuggling, commercial fraud work, and prevent illegal importation of goods from the Tax-Free Zone into Vietnam's mainland.

- Inspecting and supervising goods and transport vehicles, preventing smuggling and illegal transportation of goods across borders; organizing the implementation of tax laws for exported and imported goods; organizing customs stations according to regulations, suitable to the geographical characteristics of the Tax-Free Zone to effectively fulfill assigned tasks.

4. The Ha Tinh Provincial Tax Department is responsible for guiding enterprises to implement Point e, Clause 1.1, Section II, of this Circular and other tax-related contents.

5. This Circular takes effect fifteen days after its publication in the Official Gazette. Any difficulties encountered during implementation should be reported to the Ministry of Finance for research and supplementary guidance./.