OFFICIAL OFFICE 1070 / CTHN-TTHT FOR INTEREST- FREE RATE LOANS FROM MOTHER COMPANY
Official Letter 1070 / CTHN-TTHT on interest-free loan from parent companies overseas as follows:
In principle, the case where an enterprise lends money without interest to organizations and individuals is the activity of borrowing money at no ordinary transaction price in the market, in the case of tax imposition as prescribed in Article 50. Law on tax administration No. 38/2019 / QH14. In case the transaction of the Company is not a loan transaction, the Parent Company does not generate income from supporting the Company, is not subject to the application as prescribed in Article 1 of Circular No. 103/2014. / TT-BTC dated August 6, 2014 of the Ministry of Finance, is considered not to impose tax on this transaction.