On 23 August 2016, Ho Chi Minh Department of Taxation issued Official letter No. 8127/CT-TTHT. Accordingly, in case that the company uses Group’s common email management system provided by foreign company under the same Group and pays usage fee for this company, then this income is subject to foreign contractor tax under the provisions of Circular No. 103/2014/TT-BTC. When paying to the foreign company, the company should deduct, declare and pay VAT at the rate of 5% and CIT at the rate of 10%.