On February 27th, 2025, the Hai Phong City Tax Department issued Official Letter No. 752/CTHPH-TTHT, accordingly:
In case the Company hires a foreign Company to perform services for the Company’s customers abroad, the foreign Company carries out the transportation of goods from domestic ports (after completing customs procedures) to foreign countries and performs the following tasks such as customs procedures for import in foreign countries, warehousing,… and invoices the Company for the services perform by the foreign Company:
Regarding the determination of foreign contractor tax obligations:
– For income received by the foreign contractor from the performance of services: international transportation services from Vietnam to foreign countries, international delivery, and warehousing services from Vietnam to foreign countries (regardless of whether the sender or recipient pays for the service), are subject to FCT according to the regulations of Articles 12 and 13 of Circular No. 103/2014/TT-BTC dated August 06th, 2014 of the Ministry of Finance.
– For income received by foreign organizations and individuals from services provided and consumed outside Vietnam: Subject to non-application of tax to foreign contractors according to the regulations of Clause 3, Article 2 of Circular No. 103/2014/TT-BTC dated August 06th, 2014 of the Ministry of Finance.
