On April 04th, 2025, the Tax Department issued Official Letter No. 469/CT-CS, accordingly:
According to the regulations of Clause 2, Article 5 of Circular No. 48/2019/TT-BTC, investments in domestic economic organizations, are not securities investments subject to the regulations on provision for loss of investments. Based on the regulations of Article 84 of the Civil Code No. 91/2015/QH13 and Clause 1, Article 44 of the Law on Enterprises No. 59/2020/QH14, a branch is a dependent unit of a legal entity, not a legal entity.
Therefore, the capital allocated by the Company to its Branch is not subject to the regulations of Clause 2, Article 5 of Circular No. 48/2019/TT-BTC, and is not eligible for provision for loss of investments.
