On May 07th, 2025, the Regional Tax Sub-Department XIX issued Official Letter No. 254/CCTKV.XIX-QLDN2, accordingly:
In case the Company borrows at least 10% of the owner’s capital contribution during the tax period from the General Director and his wife (the owner of a business household), the Company and the General Director and his wife (the owner of an individual business household) shall be determined as related parties.
In case the General Director and his wife (the owner of an individual business household) only sign contracts to supply products and goods to the Company, and do not engage in any transactions to transfer or receive transfer of at least 25% of the owner’s capital contribution of the enterprise during the tax period; borrowing or lending at least 10% of the owner’s capital contribution at the time the transaction arises during the tax period with individuals managing or controlling the enterprise or with individuals having relationships as defined by regulations, the Company and the above individuals shall not be determined as parties having related party transactions according to the regulations in Article 5 of Decree No. 132/2020/ND-CP.
