Official document No. 3544/QNG-QLDN1 Issued by the Quang Ngai Provincial Tax Department on December 11, 2025, this is a key operational guidance document aimed at specifying the regulations at Corporate Income Tax Law No. 67/2025/QH15. In the context of significant changes in the tax legal system, this document serves as a "guide" to help businesses in Quang Ngai province and neighboring areas accurately determine their tax incentive rights for investment expansion activities after October 1, 2025.
Understanding the content of Official Letter No. 3544/QNG-QLDN1 not only helps chief accountants and financial directors avoid errors in tax settlement but also optimizes cash flow through legitimate tax exemption and reduction policies. The appearance of this document thoroughly resolves the difficulties regarding the separate accounting of additional income and the technical criteria for the original cost of fixed assets. Let's delve into the key changes below with MAN – Master Accountant Network.
Legal context: Corporate Income Tax Law No. 67/2025/QH15 and its effective date.
The issuance of Official Document No. 3544/QNG-QLDN1 is closely linked to the milestone of October 1, 2025, when the Law comes into effect. corporate income tax It has just officially come into effect. This is a crucial transitional phase, requiring utmost caution in controlling the legal documents and records of the investment project.
The relationship between Official Letter No. 3544/QNG-QLDN1 and Article 12 of the Corporate Income Tax Law
Article 12 of the Corporate Income Tax Law No. 67/2025/QH15 establishes the basis for determining the scope of incentives. Official Letter No. 3544/QNG-QLDN1 explains that projects that disburse capital after the law comes into effect will have to comply with the new conditions regarding capital scale and technology.
Scope of application of Official Letter No. 3544/QNG-QLDN1 in Quang Ngai
This document focuses on providing guidance to businesses with investment projects in industrial parks and economic zones within the province. It is particularly relevant for businesses with stable production and business operations, those upgrading their production lines, or expanding their production scale.
Incentives for expansion investment projects as per Official Letter No. 3544/QNG-QLDN1
The central content of Official Letter No. 3544/QNG-QLDN1 divides the beneficiaries of preferential treatment into two distinct groups based on the status of the original project. This helps eliminate confusion in applying preferential tax rates and exemption periods.
In the case where the original project is already enjoying tax incentives.
According to the guidelines in section 14.5a of the new law and Official Letter No. 3544/QNG-QLDN1, if the current project is still within the period of enjoying preferential tax rates or exemptions, the additional income from the expansion investment will "follow" the original project.
| Content | Regulations as per Official Letter No. 3544/QNG-QLDN1 |
| Discount level | Benefits based on the original project's rates (Tax rates and Exemptions/Reductions). |
| Duration of entitlement | For the remaining time of the original project |
| Accounting requirements | It is not mandatory to separately account for additional income. |
| Legal basis | Article 14.5a of Law No. 67/2025/QH15 |
Evidence from Official Letter No. 3544/QNG-QLDN1 shows that this is a major administrative reform, helping to reduce the burden of accounting paperwork for businesses that are on a path of rapid development.
In cases where the original project has exceeded the period of preferential treatment.
For long-established businesses, Official Letter No. 3544/QNG-QLDN1 notes that the expansion investment portion still has the opportunity to be exempted., Corporate income tax reduction If they meet the industry and geographical criteria.
From a professional perspective at MAN, we note that Circular No. 3544/QNG-QLDN1 emphasizes that businesses are only entitled to tax exemptions and reductions (e.g., exemption for 2 years, reduction of 50% for the following 4 years) and are not allowed to reapply preferential tax rates (such as 10% or 15%). This needs to be carefully considered when developing long-term financial plans.
Technical criteria for eligibility for incentives as per Official Letter No. 3544/QNG-QLDN1
To be eligible for incentives, an expansion project cannot exist solely on paper. Official document No. 3544/QNG-QLDN1 requires proof of actual capital flows and assets.
Criteria for the original cost of fixed assets
According to Section 14.6a mentioned in Official Letter No. 3544/QNG-QLDN1, the project must achieve a minimum increase in the original cost of fixed assets as stipulated by the Government. The determination of this original cost must be based on valid invoices and supporting documents and must be completed and accepted.
Time of calculating tax exemption period
Official document No. 3544/QNG-QLDN1 clarifies: The tax exemption and reduction period for expansion investments begins from the year the investment capital is completed and production and business operations commence. This is a crucial timeframe that accountants need to accurately record in their books.
Accounting responsibilities and risks from Official Letter No. 3544/QNG-QLDN1
One of the most contentious issues in tax administration is income allocation. Circular No. 3544/QNG-QLDN1 has provided specific solutions to this problem to ensure transparency.
Allocation method when separate accounting is not possible.
If a business cannot separate income from the expansion, Circular No. 3544/QNG-QLDN1 provides guidance on using the following ratio formula:
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Income eligible for tax incentives = (Original cost of newly invested fixed assets / Total original cost of actual fixed assets) × Total taxable income |
Applying this formula according to Official Letter No. 3544/QNG-QLDN1 ensures fairness but may reduce the amount of tax incentives if businesses do not proactively monitor their input costs separately.
FAQ – Frequently Asked Questions about Official Document No. 3544/QNG-QLDN1
According to Official Letter No. 3544/QNG-QLDN1, projects that have already commenced operations and are enjoying incentives before this date will continue to operate under the old regulations until the end of the incentive period, unless there are new adjustments to capital disbursement after October 1, 2025.
Although Circular No. 3544/QNG-QLDN1 does not mandate it directly, to ensure the accuracy of the criteria for separating original cost and income, tax authorities often encourage businesses to use independent auditing services to verify the data. Does the investment expansion project before October 1, 2025, apply Circular No. 3544/QNG-QLDN1?
Does Official Letter No. 3544/QNG-QLDN1 mandate auditing of tax incentive reports?
Conclude
Official Document No. 3544/QNG-QLDN1 is an important legal document that all businesses in Quang Ngai need to carefully study in order to correctly implement the Corporate Income Tax Law 2025. Misunderstanding or failing to apply the conditions in Official Document No. 3544/QNG-QLDN1 can lead to tax arrears and late payment penalties amounting to large sums, directly affecting the reputation and finances of the business.
With extensive experience in Accounting, Auditing, and Taxation, MAN – Master Accountant Network proudly serves as a trusted partner helping businesses decipher the complexities of Official Letter No. 3544/QNG-QLDN1. We provide auditing services Tax incentives, accounting record reviews, and advice on the most optimal investment structure. Don't let policy barriers slow your progress. Contact MAN today to receive support from our team of experts in implementing the spirit of Circular No. 3544/QNG-QLDN1 and protecting your business interests.
Service contact information at MAN – Master Accountant Network
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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.
