Official lteer 1221/TCT-CS dated april 16th 2013 by gdt guiding on corporate taxable income for foreign contractor
According to the guidance in the official letter 1221/TCT-CS:
If Company A in foreign country sign the contract with Company B based in Vietnam to supply machinery. The contract specify overseas delivery location and Company B bears all the costs to bring the machinery into Vietnam such as transport cost, insurance,…If Company A may offer accompanying assembly services which are rendered in Vietnam then Company A is foreign contractor according to Circular 60/2012/TT-BTC