On January 08th, 2021, Hanoi Tax Department issued Official Letter No. 1070/CTHN-TTHT, whereby:
Fundamentally, if the enterprises conduct interest-free loans for organizations, individuals, it shall be determined as capitial borrowing activities which against its market prices, and subjected to tax liability imposition case as regulated in Article 50 Law on Tax Administration No. 38/2019/QH14. By contrast, if the transaction of the Company is not determined as a loan, and the parent company does not incur any income from its supporting activities for the subsidiary company, and not also subjected to applicable cases as prescribed in Article 1 Circular No. 103/2014/TT-BTC issued by the Ministry of Finance on August 06th, 2014, it will be considered for not applying the tax liability imposition.
