On July 30, 2025, the Bac Ninh Provincial Tax Department issued Official Letter No. 1446/BNI-QLDN3 regarding the refund of value-added tax (VAT) for imported goods subsequently sold to export processing enterprises (EPEs). The details are as follows:
1. Eligible entities for VAT refund:
Enterprises having exported goods or services with input VAT not yet credited amounting to VND 300 million or more shall be entitled to a VAT refund, except for cases where imported goods are subsequently exported to another country.
For this purpose, goods imported and subsequently exported to another country refer to goods imported by enterprises from abroad into Vietnam and then directly exported or entrusted for export, excluding goods imported as raw materials for the production or processing of exported goods
(According to Article 15.1 of the Law on Value Added Tax 2024)
2. Definition of “export” and “export processing zone”
Export of goods means the transportation of goods out of the territory of Vietnam or into a special zone located within the territory of Vietnam that is considered a separate customs area under law.
An export processing zone is an industrial zone specialized in manufacturing exported goods, providing services for the production of exported goods and export activities, separated from domestic areas and subject to regulations applicable to non-tariff zones
(According to Article 28.1 of the Commercial Law 2005 and Article 2.2 of Decree 35/2022/ND-CP)
Based on the foregoing provisions, in cases where enterprises import goods and fully pay VAT at the import stage, and subsequently resell such goods to an export processing enterprise, the sales transaction shall be deemed as an export into an export processing zone rather than an export abroad. Accordingly, such enterprises remain eligible for VAT refund in accordance with regulations.
(According to Official Letter No. 1446/BNI-QLDN3 dated July 30, 2025)
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