OFFICIAL LETTER NO. 1456/TCT-CS DATED 16 APR 2015 OF GDT IN GUIDANCE OF CIT FOR CAPITAL TRANSFER AND INTEREST TO CONTRIBUTE INVESTMENT CAPITAL
According to official letter No. 1456/TCT-CS:
In case, the company incurred loss when the capital is transferred, it will be offset to taxable income of the activities arising income (excluding income from real estate transfer, project transfer (excluding attachment with land use right transfer, land rent right transfer); income from project implementation right transfer; exploration, mining, mineral processing, rights transfer under regulations of Law) chosen by enterprises.
In case, the company borrows money to contribute the capital to project after transferring the contribution capital with loss and has not yet paid the bank debts therefore, continuing to incur interest payable to bank, this payable interest is not included in deductible expense when determining taxable income of the company.
From 01 Jan 2015, if the enterprises’ charter capitals are contributed fully, during business process, if there are the interests payable to invest in other enterprises, these amounts are included in deductible expense when determining taxable income of the company.
