How to calculate deductible lịch trực tiếp bóng đá hôm nay in related-party transactions for PIT calculation in Vietnam?
How to calculate deductible lịch trực tiếp bóng đá hôm nay in related-party transactions for PIT calculation in Vietnam?
Pursuant to points a and b, clause 3, Article 16 ofDecree 132/2020/ND-CP, which stipulates lịch trực tiếp bóng đá hôm nay determination of costs for tax calculation for enterprises with related-party transactions for PIT calculation as follows:
Determination of costs for tax calculation for enterprises with related-party transactions
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3. Total deductible lịch trực tiếp bóng đá hôm nay when determining the taxable income of enterprises with related-party transactions:
a) Total lịch trực tiếp bóng đá hôm nay after subtracting interest from deposits and loans arising during the tax period of the taxpayer are deductible when determining the taxable income of the enterprise, which do not exceed 30% of the total net profit from business activities during the tax period plus lịch trực tiếp bóng đá hôm nay after subtracting interest from deposits and loans arising during the period plus depreciation costs arising during that taxpayer's period;
b) The non-deductible portion of lịch trực tiếp bóng đá hôm nay under point a of this clause may be transferred to the following tax period when determining the total deductible lịch trực tiếp bóng đá hôm nay, provided the total deductible loan interest incurred in the subsequent tax period is less than what is stipulated at point a of this clause. The duration of transferring lịch trực tiếp bóng đá hôm nay is continuous and not exceeding 5 years from the year following the year the non-deductible lịch trực tiếp bóng đá hôm nay arise;
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In summary, according to the above regulations, the deductible loan lịch trực tiếp bóng đá hôm nay cost in related-party transactions for CIT calculation is determined as follows:
- Total lịch trực tiếp bóng đá hôm nay, after subtracting interest from deposits and loans arising during the period of the taxpayer, are deductible when determining taxable income for CIT, which do not exceed 30% of the total net profit from business activities during the tax period plus lịch trực tiếp bóng đá hôm nay after subtracting interest from deposits and loans arising during the period plus depreciation costs arising during that period for the taxpayer.
- The portion of non-deductible lịch trực tiếp bóng đá hôm nay will be transferred to the following tax period to determine the total deductible lịch trực tiếp bóng đá hôm nay if the total deductible loan interest incurred for the subsequent tax period is less than 30% of the total net profit from business activities during the period plus lịch trực tiếp bóng đá hôm nay after subtracting interest from deposits and loans arising during the period plus depreciation costs incurred during the period by the taxpayer.
The transfer period of lịch trực tiếp bóng đá hôm nay is continuous and not exceeding 5 years from the year following the year the non-deductible lịch trực tiếp bóng đá hôm nay arise.
Note:The aforementioned deductible lịch trực tiếp bóng đá hôm nay in related-party transactions do not apply to loans of taxpayers who are: credit institutions, insurance business organizations, loans supported by official development assistance (ODA), concessional loans from the Government of Vietnam, loans for national target programs, and loans for investment programs or projects implementing the state's social welfare policies.
How to calculate deductible lịch trực tiếp bóng đá hôm nay in related-party transactions for PIT calculation in Vietnam?(Image from lịch trực tiếp bóng đá hôm nay Internet)
What are cases wheretaxpayers are exempt from declaring and preparing transfer pricing declaration in Vietnam?
Pursuant to Article 19 ofDecree 132/2020/ND-CP, it stipulates lịch trực tiếp bóng đá hôm nay cases in which taxpayers are exempt from declaring and preparing transfer pricing declaration as follows:
- Taxpayers are exempt from declaring lịch trực tiếp bóng đá hôm nay determination of transfer pricing at Section III, Section IV Annex I issued withDecree 132/2020/ND-CP, and exempt from preparing transfer pricing declaration according to lịch trực tiếp bóng đá hôm nay regulation in this Decree if transactions arise only with related parties that are subject to corporate income tax in Vietnam, applying lịch trực tiếp bóng đá hôm nay same corporate income tax rate as lịch trực tiếp bóng đá hôm nay taxpayer, and none receives preferential corporate income tax during lịch trực tiếp bóng đá hôm nay tax period. However, they must declare lịch trực tiếp bóng đá hôm nay grounds for exemption at Section I, Section II of Annex I issued withDecree 132/2020/ND-CP.
- Taxpayers have lịch trực tiếp bóng đá hôm nay responsibility to declare lịch trực tiếp bóng đá hôm nay determination of transfer pricing according to Annex I issued withDecree 132/2020/ND-CP, but are exempt from preparing transfer pricing declaration in lịch trực tiếp bóng đá hôm nay following cases:
+ Taxpayers have related-party transactions but lịch trực tiếp bóng đá hôm nay total revenue arising in lịch trực tiếp bóng đá hôm nay tax period is below VND 50 billion and lịch trực tiếp bóng đá hôm nay total value of all related-party transactions in lịch trực tiếp bóng đá hôm nay tax period is below VND 30 billion;
+ Taxpayers have entered into Advance Pricing Arrangements and submit Annual Reports according to legal regulations on Advance Pricing Arrangements. Related-party transactions not covered by lịch trực tiếp bóng đá hôm nay Advance Pricing Arrangement, taxpayers must still declare lịch trực tiếp bóng đá hôm nay determination of transfer pricing according to regulations at Article 18 ofDecree 132/2020/ND-CP.
- Taxpayers engaged in business with simple functions, not incurring revenue, and expenses from the exploitation or use of intangible assets, with revenue below VND 200 billion, applying a profit margin before lịch trực tiếp bóng đá hôm nay and corporate income tax (excluding differences in financial revenue and expenses) on net revenue, including the following sectors:
- Distribution: from 5% and above;
- Production: from 10% and above;
- Processing: from 15% and above.
In cases where taxpayers track and account for revenue and expenses separately by sector, apply the profit margin before lịch trực tiếp bóng đá hôm nay and corporate income tax on net revenue applicable to each sector. In cases where taxpayers track and account for revenue separately but not expenses for each field of production and business, allocate expenses according to the revenue proportion of each field to apply the profit margin before lịch trực tiếp bóng đá hôm nay and corporate income tax on net revenue applicable to each sector.
In cases where taxpayers neither track nor account for revenue and expenses separately by each field of their production and business activities to determine the profit margin before lịch trực tiếp bóng đá hôm nay and corporate income tax applicable to each sector, apply the profit margin before lịch trực tiếp bóng đá hôm nay and corporate income tax on net revenue from the sector with the highest profit margin.
In cases where taxpayers do not apply profit margins according to this regulation, they must prepare transfer pricing declaration as specified.
- Taxpayers are eligible for exemption from declaring, preparing transfer pricing declaration according to clause 1, clause 2 of Article 16 ofDecree 132/2020/ND-CP. The determination of the total deductible lịch trực tiếp bóng đá hôm nay for determining taxable corporate income of enterprises with related-party transactions is performed pursuant to clause 3, Article 16 ofDecree 132/2020/ND-CP.
What are related-party transactions?
Pursuant to clause 22, Article 3 of lịch trực tiếp bóng đá hôm nayLaw on Tax Administration 2019, related-party transactions are defined as follows:
Interpretation of terms
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22. Related-party transaction is a transaction between parties with a relationship.
23. Independent transaction is a transaction between parties without a relationship.
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Thus, according to lịch trực tiếp bóng đá hôm nay above regulations, a related-party transaction is a transaction between parties that have a relationship.