On September 30th, 2024, the Lao Cai Provincial Tax Department issued Official Letter No. 6781/CT-TTHT, accordingly:
In case the Company (the Buyer) signs a contract with another company (the Seller) to carry out a construction consulting package to serve its production and business activities. The Seller designates the authorized payment through a third party, the contents of the service contract between the two parties must stipulate the scope, content of the authorized tasks, the rights and obligations of the authorizing party and the authorized party, and the duration of the authorization contract. The third party receiving the authorization must be a legal entity or an individual operating according to the provisions of law.
Based on the above regulations and the Company’s actual situation, deductible expenses when calculating CIT must meet the conditions stipulated in Article 6 of Circular No. 78/2014/TT-BTC (as amended and supplemented in Article 4 of Circular No. 96/2015/TT-BTC dated June 22nd, 2015) of the Ministry of Finance.