Decree No. 181/2025/ND-CP - VAT rate for services provided to Export Processing Enterprises
Specifically, a new condition has been added requiring that the services must be “provided directly to organizations located within non-tariff zones and consumed within those zones to directly serve export production activities”.
Discussions with tax authorities indicate two prevailing interpretations on how to determine eligible services:
- Direct vs. indirect services: Only services directly connected to export production—such as those linked to production lines, machinery, or manufacturing—qualify for the 0% VAT rate.
Administrative or support services are generally considered indirect and thus not eligible. - Scope of EPE operations: Where an EPE engages solely in export production, services provided to it may qualify for the 0% VAT rate. However, if the EPE also conducts domestic business activities, each service must be reviewed to determine whether it supports export or non-export activities.
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