OFFICIAL LETTER

ON CONTRACTOR TAX POLICIES

To: Vietnam Showpla Ltd. Company

In response to Official Letter No. 37/CT of July 19, 2007, of Vietnam Showpla Ltd. Company, requesting guidance on issues in tax policies, the General Department of Taxation gives the following opinions:

Pursuant to the provisions of Section III, Part B of the Finance Ministry’s Circular No. 128/2003/TT-BTC of December 22, 2003, guiding the implementation of the Government’s Decree No. 164/2003/ND-CP of December 22, 2003, detailing the implementation of Law on Business Income Tax regarding deductible reasonable expenses for taxable income calculation.

In case Vietnam Showpla Ltd. Company signs contracts with foreign contractors without application of the Vietnamese accounting regime for the provision of general management services, declares and pays business income tax on behalf of foreign contractors, it may account the contract value and business income tax amounts payable by foreign contractors as reasonable expenses when determining business income tax-liable incomes.

The General Department of Taxation gives this guidance to Vietnam Showpla Ltd. Company for compliance.

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FOR THE GENERAL DIRECTOR OF TAXATION
DEPUTY GENERAL DIRECTOR




Pham Duy Khuong

Công văn số 3959/TCT-CS về Chính sách thuế nhà thầu do Tổng cục Thuế ban hành