Official document No. 330/CT-CS The Tax Department's Circular No. 330/CT-CS dated January 20, 2026, is an important legal document clarifying issues regarding Value Added Tax (VAT) policy and the method of determining the original cost of fixed assets for interest expense deductions. In the context of businesses continuously expanding their investments, correctly understanding the spirit of Circular No. 330/CT-CS helps accountants comply with regulations on invoices and supporting documents and optimize deductible expenses when settling corporate income tax.
Based on core legal foundations such as Circular 219/2013/TT-BTC and Circular 45/2013/TT-BTC, Circular No. 330/CT-CS thoroughly resolves the confusion of local tax authorities regarding the classification of entities exempt from VAT for lending activities. This document serves not only as a guide for the Hue City Tax Authority but also as a valuable reference for the accounting and auditing community nationwide. Let's delve into the key details below with MAN – Master Accountant Network.
Legal context and the issuance of Official Letter No. 330/CT-CS
The issuance of Official Letter No. 330/CT-CS stemmed from Official Letter No. 1492/CCTKVXII-TTKT-HUE of the Tax Department of Region XII, which encountered difficulties during the process of reviewing actual records. Determining whether interest expenses can be capitalized and the related VAT obligations is a complex issue requiring coordination among many specialized circulars.
To clarify the content of Official Letter No. 330/CT-CS, the Tax Department cited a vast system of legal documents, creating legal rigor:
- Article 112 of the Law on Tax Administration No. 38/2019/QH14 on the authority to conduct inspections.
- Circular 219/2013/TT-BTC provides detailed guidance on Value Added Tax (VAT).
- Circular 45/2013/TT-BTC regulates the management and depreciation of fixed assets.
- Accounting Standard No. 16 (VAS 16) on “Borrowing Costs” according to Circular 161/2007/TT-BTC.
| Legal documents | Main adjustments | Role in Official Document 330 |
| Tax Law 38/2019/QH14 | Authority of the head of the tax agency | Determine the authority responsible for processing the application. |
| Circular 219/2013/TT-BTC | Tax-exempt items and taxable value | Guidelines on VAT on loan interest |
| Circular 45/2013/TT-BTC | Original cost of tangible fixed assets | Regulations on the capitalization of loan interest |
| Circular 161/2007/TT-BTC | Accounting Standard No. 16 | Techniques for managing borrowing costs |
Resolving issues related to VAT according to Official Letter No. 330/CT-CS
In Official Letter No. 330/CT-CS, the issue of VAT on interest income is given top priority. According to Clause 8, Article 4 of Circular 219/2013/TT-BTC, lending activities are exempt from VAT. However, in practice, errors have arisen regarding the timing and price of tax calculation.
Identifying items not subject to VAT.
The Tax Department, through Official Letter No. 330/CT-CS, requires local tax authorities to clearly distinguish which portion of interest expenses are actually tax-exempt. This is extremely important because incorrect identification could lead to businesses issuing invoices that violate regulations, resulting in administrative tax penalties.
Time and price for calculating VAT
The reference to Clause 9 of Article 7 and Clause 5 of Article 8 of Circular 219 in Official Letter No. 330/CT-CS reminds businesses of the importance of timeliness. For construction and installation activities involving borrowed capital, the time for determining the taxable price is the time of acceptance and handover of the project item, regardless of whether payment has been received or not.
Determining the original cost of tangible fixed assets based on the spirit of Official Letter No. 330/CT-CS
One of the most significant points of Circular No. 330/CT-CS is the affirmation of capitalizing interest expense. This is a matter of particular interest to businesses in the project investment phase, aiming to increase asset value and optimize depreciation costs later on.
Conditions for interest expense to be included in the cost of goods sold.
According to Official Letter No. 330/CT-CS, interest expense is added to the original cost of fixed assets if it arises during the investment, purchase, or construction of the asset. A prerequisite is that these expenses must be incurred up to the point when the asset is ready for use. After this point, interest expense must be accounted for as financial expense in the current period.
Instructions for applying Circular 45/2013/TT-BTC
Businesses should note that Official Letter No. 330/CT-CS emphasizes compliance with Circular 45. The original cost of purchased tangible fixed assets includes: Actual purchase price (+) Non-refundable taxes (+) Directly related costs including investment loan interest.
| Cost category | Amount (VND) | Classification according to Official Document 330 |
| Price of machinery and equipment | 5.000.000.000 | Original price |
| Interest on loans during the installation process. | 200.000.000 | Add to original cost (Market capitalization) |
| Interest on loans after the machine is operational. | 50.000.000 | Financial expenses during the period |
| Costs of testing assets | 30.000.000 | Add to the original price |
| Total original cost of fixed assets | 5.230.000.000 | Depreciation value |
Responsibilities of the inspection unit and factual documentation as per Official Letter No. 330/CT-CS
Official document No. 330/CT-CS does not offer a "fixed" answer but requires local tax authorities to base their decisions on "actual records obtained through inspection." This places high demands on the integrity and completeness of accounting documents within businesses.
The role of Article 112 of the Law on Tax Administration
The Tax Department affirmed in Official Letter No. 330/CT-CS the authority of the head of the tax agency in issuing inspection decisions. Businesses need to prepare loan agreements, disbursement documents, and detailed interest calculation sheets to demonstrate the reasonableness of the accounting data.
Coordination between accountants and tax authorities
Through Official Letter No. 330/CT-CS, we clearly see the importance of policy dialogue. Businesses in Hue in particular and the whole country in general need to closely follow the guidelines in this document to review their documents before inspections by authorities, avoiding regrettable mistakes. VAT interest on loans.
Conclude
Official Document No. 330/CT-CS is a detailed guidance document that resolves bottlenecks in handling financial costs in asset investment. Understanding Official Document No. 330/CT-CS helps businesses comply with the law and optimize cash flow through accurate depreciation. In the context of increasingly stringent tax regulations, staying updated on documents like Official Document No. 330/CT-CS is mandatory for professional accountants.
To ensure the absolute safety of their financial system, businesses need to find a reputable consulting firm. MAN – Master Accountant Network is proud to offer these services. auditing services, tax accounting, and tax consulting services In-depth. We help handle issues related to Official Letter No. 330/CT-CS, and implement them. tax settlement and tax reporting The most professional. Let MAN be your partner in the sustainable development of your business.
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Content production by: Mr. Le Hoang Tuyen – Founder & CEO MAN – Master Accountant Network, Vietnamese CPA Auditor with over 30 years of experience in Accounting, Auditing and Financial Consulting.
Frequently Asked Questions about Official Document No. 330/CT-CS
No. Official document No. 330/CT-CS focuses on interest expenses incurred during the investment and purchase of fixed assets. Interest expenses for normal business operations will be accounted for as financial expenses in the period, as stipulated by the Corporate Income Tax Law and Circular 78/2014/TT-BTC.
Businesses have the full right to declare supplementary adjustments to the original cost of fixed assets if they have sufficient supporting documentation in accordance with the spirit of Official Letter No. 330/CT-CS, provided that this is done before the tax authorities announce a decision to conduct an on-site inspection.
This regulation aims to encourage capital circulation. Credit granting services (including lending) are regulated by the state as exempt from VAT, in order to reduce the financial burden on borrowers in the economy. Are the interest rates on regular business loans subject to Circular No. 330/CT-CS?
Is it possible to readjust the original cost if interest capitalization is omitted according to Official Letter No. 330/CT-CS?
Why is interest expense exempt from VAT as mentioned in Official Letter No. 330/CT-CS?
