{"id":4535,"date":"2026-02-09T11:43:31","date_gmt":"2026-02-09T04:43:31","guid":{"rendered":"https:\/\/thue.man.net.vn\/?p=4535"},"modified":"2026-02-09T15:31:39","modified_gmt":"2026-02-09T08:31:39","slug":"cong-van-so-454","status":"publish","type":"post","link":"https:\/\/thue.man.net.vn\/en\/cong-van-so-454\/","title":{"rendered":"Official Document No. 454\/CT-CS: New points regarding capital transfer tax for foreign enterprises."},"content":{"rendered":"

Official document No. 454\/CT-CS<\/span><\/a> The document issued by the Tax Department on January 23, 2026, is considered a key guiding document in the implementation process. <\/span>Decree 320\/2025\/ND-CP<\/span><\/a> Regarding corporate income tax on capital transfer activities of foreign enterprises, this document not only clarifies the method of calculating tax at the rate of 2% on revenue but also standardizes the application time and tax declaration forms on the electronic system.<\/span><\/p>\n

In the context of increasing M&A and restructuring activities involving foreign elements, Circular No. 454\/CT-CS serves as a guiding principle to help businesses, chief accountants, and auditors mitigate the risks of errors, tax arrears, and penalties. This article will comprehensively analyze the new points, practical impacts, and effective compliance roadmap.<\/span><\/p>\n

Download the article summary here.<\/a><\/strong><\/span><\/p>\n

Legal overview of Official Letter No. 454\/CT-CS<\/b><\/h2>\n
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Legal overview of Official Letter No. 454_CT-CS<\/figcaption><\/figure>\n

Circular No. 454\/CT-CS was issued in the context of significant changes in tax policies regarding capital transfers by foreign investors under Decree 320\/2025\/ND-CP. Practical difficulties arising from its application, particularly concerning the determination of tax obligations and electronic declaration, necessitate unified guidance from the central tax authority. Therefore, understanding the context and legal basis of this circular is crucial for businesses to apply it correctly and fully.<\/span><\/p>\n

Context for the issuance of Official Letter No. 454\/CT-CS<\/b><\/h3>\n

Official Letter No. 454\/CT-CS was issued to address the difficulties faced by the Hanoi City Tax Department regarding the application of Decree 320\/2025\/ND-CP to the capital transfer activities of foreign investors. In reality, many FDI enterprises have not yet agreed on how to determine their obligations. <\/span>corporate income tax<\/span><\/a> when transferring equity stakes in Vietnamese businesses.<\/span><\/p>\n

The lack of synchronization between new legal regulations and the electronic tax filing system has created an urgent need for specific guidance from the Tax Department. Circular No. 454\/CT-CS was issued to address this gap and ensure uniformity throughout the tax sector.<\/span><\/p>\n

Legal basis cited<\/b><\/h3>\n

The content of Official Letter No. 454\/CT-CS is based on the following key legal grounds:<\/span><\/p>\n