On September 22nd, 2020 Bac Ninh Tax Department issued Official Letter No. 3042/CT-TTHT. Whereby:
When the Company converts loaned capital. loan interests into contribution capital of the foreign investor, then:
The interest expense that the Company has accrued for the financial expenses shall be determined as deductible expenses when calculating the CIT if these costs meet the conditions in Clause 1 Article 4 Circular No. 96/2015/TT-BTC dated June 22nd, 2015 issued by the Ministry of Finance.
The Company must make FCT payment on behalf of the investor for the loan interests up to the moment of loan capital conversion to the contribution capital as regulated in Clause 3 Article 7 and Article 11 Circular No. 103/2014/TT-BTC dated August 6th, 2014 issued by the Ministry of Finance.
