TX - Mock test - Đề bài

TAXATION (VNM) – MOCK TEST
SECTION A
1.
Sung Soo Co, a korean contractor, who does not follow Vietnamese accounting system
(VAS), signs a contract with Lorry Co in Vietnam to provide compressor machine and
spareparts equipment with installation and test run services for USD 20 million. The
contract does not separate the value of compressor machine and spareparts equipment
from the value of services.
What is the VAT rate for FCT purposes that would be applicable to Sung Soo Co?
A. 5%
B. 3%
C. 2%
D. Not subject to VAT
2.
In 2021, Jonny, a UK resident, entered into an agreement with THB Co, a publisher in
Vietnam. Under the agreement, Jonny grants THB Co the right to publish, in Vietnam,
his new book about coaching skills for an amount of USD150,000. Jonny’s personal
income tax (PIT) liability in Vietnam is to be borne by THB Co.
What amount of PIT liability (in VND millions, rounded to two decimals), in respect
of Jonny, will THB Co be required to pay in Vietnam under the above agreement?
A. VND185.53 million
B. VND175.75 million
C. VND176.25 million
D. VND185.00 million
3.
RFD Co is a Vietnamese company headquartered in Hanoi. In December 2021, the
company had net output value added tax (VAT) of VND2,000 million from its business
operations in Hanoi. The company also had input VAT from two investment projects,
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both of which were in the construction period and had not generated any revenue. Project
A is located in Hanoi and incurred input VAT of VND1,500 million. Project B is located
in Vinh Phuc province and incurred input VAT of VND400 million.
What is the correct treatment for the input value added tax (VAT) incurred by RFD
Co in respect of the two investment projects (assuming the relevant documents for a
VAT refund are in place)?
Input VAT of Project A Input VAT of Project B
A. Claim refund for VND1,500 million Claim refund for VND400 million
B. Claim refund for VND1,500 million Offset VND400 million with net output
VAT of VND2,000 million from operations
of headquarter
C. Offset VND1,500 million with net Claim refund for VND400 million
output VAT of VND2,000 million from
operations of headquarter
D. Offset VND1,500 million with net Offset VND400 million with the VND500
output VAT of VND2,000 million from million, being the remaining amount of net
operations of headquarter output VAT after offsetting input VAT of
project A
4.
In 2021, Mr Quang, a Vietnamese citizen with no dependants, had the following income:
• a compensation of VND2,000 million from the State, for resettlement from his
residence upon land expropriation by the State for a national project;
• a scholarship valued at USD25,000 from a university in the US for a remote
learning course (supported by sufficient entitlement documents).
What is Mr Quang’s personal income tax liability (rounded to the nearest VND
million) in the year 2021 from the above income sources?
A. VND40 million
B. VND0 million
C. VND58 million
D. VND98 million

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5.
Which of the following methods is not a method of calculating contractor tax as
prescribed?
A. Calculate VAT by the deduction method, calculate CIT on the actual revenue and
expenses to determine taxable income.
B. Calculate VAT and CIT by applying rate of each on each taxable value
C. Calculate VAT by the deduction method, calculate CIT by applying the rate on
taxable income.
D. Calculate VAT by the method of direct calculation on added value, calculate CIT
on the basis of declaration of revenue and expenses to determine taxable income
6.
Japa Co is a new foreign invested company which was established and began trading in
Vietnam by the end of 2020.
The company’s fiscal year end is 31 December 2021. Japa Co is eligible to declare value
added tax (VAT) on a monthly basis.
Which of the following combinations correctly describes the deadlines for settling
the taxes which Japa Co will be subject to in 2021?
Value added tax Provisional corporate Business registration
(VAT) income tax (CIT) fee
A. The last day of the The 30th day of the next The last day of the next
month quarter quarter
B. The 30th day of the next The 90th day of the next The 10th day of the next
month quarter year
C. The 20th day of the next The last day of the fist The last day of the first
month month of the next month of the next year
quarter
D. The last day of the next The 30th day of the next The 30th of the next
month quarter year

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7.
Mr Alaf, an Oman citizen, arrived in Vietnam to work for VFF Co from 15 April 2020.
He completed his employment on 15 November 2021 and left Vietnam. Throughout the
period from 15 April 2020 to 15 November 2021 he spent the following number of days
in Vietnam:
• From 15 April 2020 to 31 December 2020 – 126 days
• From 1 January 2021 to 14 April 2021 – 57 days
• From 15 April 2021 to 15 November 2021 – 180 days
What is Mr Alaf’s tax residency status for both his first and second tax years in
Vietnam, based on the above information?
First tax year Second tax year
Option 1 Resident Non-resident
Option 2 Non-resident Resident
Option 3 Non-resident Non-resident
Option 4 Resident Resident
A. Option 1
B. Option 2
C. Option 3
D. Option 4
8.
A Vietnamese company, Chien Thang Co, has an income of VND850 million from
investment projects abroad. Chien Thang Co gained the income after having paid the CIT
of VND250 million according to the aboard law.
What is the amount of CIT that Chien Thang Co has to pay in Vietnam?
A. No need to additional pay the CIT in Vietnam
B. VND170 million
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C. VND220 million
D. VND80 million
9.
According to Decree 132/2020, ‘Standard arm’s length range’ is a set of values ranging
from a lower percentile to an upper percentile.
What are the lower and upper percentiles for ‘Standard arm’s length range’ as
stipulated in Decree 132/2020?
Lower Upper
Option 1 25th 75th
Option 2 25th 65th
Option 3 35th 75th
Option 4 35th 65th
A. Option 1
B. Option 2
C. Option 3
D. Option 4
10.
On 25 June 2021, the local tax authorities of LPP Co, a Vietnamese company, issued a
minute of tax audit stating that the company made an under-declaration of corporate
income tax (CIT) of VND 25,000 million for the year ended 31 December 2020. The
deadline for tax payments for this period was 31 March 2021. The tax authorities also
issued a decision for tax and penalty collection on 3 July 2021, and gave the company ten
days from the date of issue to settle the amount due.
What is the potential late payment interest which LPP Co would be required to pay,
if LPP Co made a settlement on the decision date of 3 July 2021?
A. VND920 million

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B. VND690 million
C. VND606 million
D. VND504 million
11.
SHL Limited, a foreign company operates in Vietnam, received a one-year loan of
VND50,000 million from Ultra Bank, a non-tax resident bank without an establishment
in Vietnam. The annual net-of-tax interest on the loan was VND5,000 million and SHL
Limited will bear the value added tax (VAT) of 5% and the corporation income tax
relating to Vietnam.
What is the amount of CIT (withholding tax) to be withheld by SHL Limited on the
interest payable to Ultra Bank?
A. VND263 million
B. VND555 million
C. VND250 million
D. VND2,630 million
12.
Enterprise B imports 1000 bottles of 39-degree wine, the price excluding special
consumption tax is VND300,000/bottle, the special consumption tax rate is 30%.
What is the VAT price of a bottle of wine?
A. VND390,000.
B. VND330,000.
C. VND429,000.
D. VND300,000.
13.
Which of the following expenses is not included in deductible expenses when
determining taxable income?

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A. Salary for business owner single-member limited liability owned by an individual.
B. The expenditure is not invoiced but has a full statement (form No.01) for the
purchase of agricultural products directly from the grower.
C. The payment for bonuses for business initiatives and improvements has specific
regulations on the payment of rewards for initiatives and improvements, and there
is a council for the acceptance of initiatives and improvements.
D. Expenses related to the loss value due to natural disasters which are not
compensated.
14.
PNLT Co, a foreign contractor from Denmark, entered into a contract for construction of
a factory in Vietnam and applied the deemed method for declaring foreign contractor tax
(FCT). The works were completed in 2020, however, there were some disputes between
PNLT Co, its suppliers and the project owner. When the disputes were settled in 2021,
PNLT Co received contractual compensation of USD 600,000 from its suppliers, but had
to pay contractual compensation of USD 550,000 to the project owner. Compensation is
treated as ‘other business activities’ for corporate income tax (CIT) purposes.
What is the amount of corporate income tax (CIT) as a portion of the foreign
contractor tax (FCT) liability incurred by PNLT Co in Vietnam in 2021, if the
company’s policy is to minimise tax under current regulations?
A. USD0
B. USD 12,000
C. USD10,000
D. USD25,000
15.
In 2021, LMC Co, a Singapore-based company, signed a turnkey contract to construct a
factory (including construction materials) for PQR Co, a Vietnamese company. The
turnkey contract price was USD20 million, gross of corporate income tax (CIT) at 2% but
net of value added tax (VAT). LMC Co purchased materials valued at USD8 million
from Vietnamese suppliers to use in the contract.

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What is the amount (in VND millions) of the CIT portion of foreign contractor tax
(FCT) that LMC Co would be liable for in relation to the contract with PQR Co,
assuming LMC Co applied the hybrid method for FCT declaration?
A. VND5,640 million
B. VND9,592 million
C. VND5,755 million
D. VND9,400 million

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SECTION B
1.
VNV Co (VNV) is a Vietnamese company owned by two shareholders, Ms Linh and Mr
Nam, with the shareholding ratio of 65% and 35%, respectively. VNV specialises in
software development and the trading of computer hardware. The company’s recent
taxable income/(tax losses) from operations have been as follows:
Year ended Software Trading of Combined total
computer hardware
31 December development
VND million
VND million VND million

2017 (cannot be separated for each activity) (9,000)
2018 8,000 7,000 15,000
2019 (10,000) 2,500 (7,500)
2020 15,500 2,000 17,500
2021 (11,000) 3,000 (8,000)
VNV is entitled to four years tax exemption plus a nine-year 50% tax reduction for its
software development activity from the first year of profits, which was in 2015. Due to
inappropriate planning, the tax exemptions available in the years 2015 and 2016 were
used inefficiently when the company made small profits but could not identify separately
from which of its activities the profits came. The software activity is also entitled to the
10% tax rate in the 15 years from the year of first revenue, which was also 2015.
The trading of computer hardware activity is subject to the common tax rate
In 2018, VNV was instructed in a written ruling by tax authorities that apart from the
guidance under the corporate income tax (CIT) Circulars, the losses must be utilised in a
consecutive manner to fully offset all profits from all activities within five years after
their incurrence.
At the end of 2021, as a result of unresolvable disputes, the shareholders decided to split
VNV into two separate companies according to their current shareholding ratio – LHV
(to be held by Ms Linh) and NHV (to be held by Mr Nam).
Required:

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(a) Calculate (in VND millions) the assessable income for corporate income tax (CIT) for
each of VNV Co’s activities in the years 2018, 2019, 2020 and 2021 and state the tax rate
applicable in each case.
Note: You should use the loss utilisation as required under the CURRENT CIT
regulations. (9 marks)
(b) Calculate (in VND millions) the tax loss carry forward to be allocated to LHV and
NHV respectively after the split. (1 mark)
(Total: 10 marks)
2.
Mr Nghi Pham, who is 47 years old and a Vietnamese citizen, is the general director of
MCP JSC (MCP) a company listed on the Vietnamese stock market.
According to his labour contract with MCP, Mr Nghi Pham’s monthly gross income is
VND280 million (covering all benefits in cash and in kind and all taxable). He is also
entitled to incentives based on the performance of the company.
At the end of 2021, MCP offered Mr Nghi Pham a ‘cashing shares award’ scheme as an
appendix to his labour contract, by which he would receive a nominal award of 1.2
million shares of MCP (with no dividend and voting rights). On 31 December 2021, MCP
would pay him an ‘award’ equal to the difference between the share price at the
beginning of 2021 (of VND12,000 per share) and that on 30 December 2021. In 2021,
MCP made a substantial profit and the share price on 30 December 2021 had increased to
VND30,000 per share.
The board of directors was very happy with Mr Nghi Pham’s performance in 2021 and
they are considering offering him additional incentives as follows:
– Option 1: a special cash bonus of VND3,600 million, payable immediately on 31
December 2021; or
– Option 2: a cash bonus of VND1,800 million, plus 130,000 shares to be awarded with
full rights to receive dividends, payable immediately on 31 December 2021. The board
plans to make a dividend payment for 2021 of VND1,000 per share in May 2022.
Mr Nghia Phan has three dependants, being his children. His compulsory insurance is
calculated based on the cap of VND29.8 million per month.
Required:

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(a) Describe the personal income tax (PIT) treatment of (1) the ‘cashing shares award’
scheme and (2) the shares awarded under Option 2 above. (5 marks)
(b) Calculate (in VND millions) Mr Nghi Pham’s PIT liability in Vietnam in the year
2021 under Option 1 above. (5 marks)
(Total: 10 marks)
3.
CSP Co (CSP) is an international supplier of foodstuff processing equipment
incorporated in Singapore. CSP intends to enter into a contract with MCD, a Vietnamese
corporation, for the supply of a large foodstuff production line in Vietnam.
The expected contract value of the production line will consist of the following (after
withholding tax in Vietnam):
– Machinery and equipment: USD35 million
– Design of the production line: USD4 million
– Supervision, installation and training: USD4.2 million
CSP is considering whether to make the contract a lump sum contract for USD43.2
million, or a contract with the value of each activity shown separately (as above).
CSP also wants to subcontract a part of the equipment supply amounting to USD8 million
to Vietnamese subcontractors.
According to the draft contract, MCD will bear all the withholding tax in Vietnam in
respect of the activities of CSP.
Required:
(a) Calculate the foreign contractor tax (FCT) applicable to CSP Co if the contract value
is stated as a lump sum of USD43.2 million. (4 marks)
(b) Calculate the FCT applicable to CSP Co if the contract value is shown separately for
each activity. (6 marks)
Note: You should make all calculations to the nearest USD thousands.
(Total: 10 marks)

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4.
VINAMEX Ltdub is a Vietnamese joint stock company which operates in various
industries and also has invested in a number of 100% owned subsidiaries in various
locations. CRDITV’s head office is in a large office building owned by the company in
the centre of Hai Duong Province (not located in an industrial park). All the business
activities of VINAMEX are subject to value added tax (VAT) and all payments are made
via a bank.
Transaction (1): VINAMEX recently finished the construction of a canteen and a
dormitory for its employees at one of its factories. The input VAT incurred was VND180
million and VND500 million for the canteen and dormitory, respectively.
Transaction (2): VINAMEX also constructed a small medical station for its employees in
the area near its head office. The employees, their family and people in the nearby area
can all have a free medical check at the station. The station will have no revenue. The
input VAT costs for the medical station were VND400 million.
Transaction (3): VINAMEX purchased a large quantity of helmets and pens all with the
company’s logo to give away to its customers for promotion purposes. The input VAT
for these promotional items was VND80 million.
Transaction (4): According to the capital contribution agreement to set up one of
VINAMEX’s subsidiaries, VINAMEX made an advanced payment of VND3,850 million
(inclusive of 10% VAT) to a vendor for the construction of a factory for the subsidiary.
The vendor has issued VAT invoices to VINAMEX for this construction, since the
subsidiary was not set up at the time of payment.
Transaction (5): VINAMEX purchased a fixed asset with a value of VND5,720 million
(inclusive of 10% VAT) and immediately transferred the assets to its subsidiary, CRDT-
X, for the same value. CRDT-X’s activities are not subject to VAT. Since it was an
internal movement of assets, VINAMEX decided to issue an order for internal movement
of assets and did not issue a VAT invoice to CRDT-X.
Transaction (6): VINAMEX purchased materials valued at VND880 million (inclusive of
10% VAT) for the production of goods to be sold to an international organisation for
non-refundable aid to Vietnam. The international organisation has provided VINAMEX
with the documents regarding their non-refundable aid.
Transaction (7): VINAMEX purchased a four-seater car for its general director for
VND1,980 million (inclusive of VAT 10%).
Required:
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For each of the transactions (1) to (7) calculate the amount of VINAMEX JSC’s
creditable or non-creditable input value added tax (VAT) giving a brief explanation for
any items which are NOT creditable in full.
Note: You should make all calculations to the nearest VND million.
(Total: 10 marks)
5.
You should assume that today’s date is 21 March 2022.
TL JSC (VTL) is a Vietnamese company, whose shares are listed on the Vietnamese
stock exchange. TL specializes in the manufacture and installation of telecommunication
equipment and in recent years has conducted several successful investment projects in
both Vietnam and overseas.
TL’s audited financial statements for 2021 show a profit before tax of VND720,000
million. The following issues have been identified as relevant to the preparation of the
company’s 2021 corporate income tax return. All amounts are stated exclusive of any
applicable value added tax (VAT), except where specifically stated otherwise.
(1) Special bonuses are offered to the management team and some employees with
exceptional performance.
However, the bonuses for 2021 were not settled by the fiscal year end of 31 December
2021. TL accrued VND16,800 million in the 2021 audited financial statement for these
bonuses, representing a 12% increase from the accrued bonuses for 2020 of VND15,000
million.
For 2020, the actual bonuses settled and paid in February 2020 were VND15,500 million.
The difference (between the accrued expenses of VND15,000 million and the actual
settlement amount) of VND500 million was recorded as an additional expense in the
2021 audited financial statements.
The actual bonuses for 2021 of VND16,500 million were settled and paid on 15 March
2022 (after the audited financial statements were finalised).
(2) During 2021, TL received USD5 million being the after tax profit share from its
investment project in Taiwan.
The profits had been subject to the common income tax rate in Taiwan of 17%.
(3) In 2020, TL rented out an office in Ho Chi Minh City, which was not required for its
own use, for a period of five years. TL received the full rental payment for the whole
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five-year period, of VND33,000 million (inclusive of 10% VAT) on the signing of the
rental agreement. For accounting purposes TL will recognise the rental income over the
five years of the rental period (2020 to 2024) but for tax purposes it elected to treat the
whole amount as taxable in 2020.
(4) During 2021, TL received and paid invoices for the medical costs of its directors
amounting to VND1,100 million. Under TL’s insurance policy with an insurer, 50% of
the medical costs will be covered by the insurer. According to the contract with the
directors, TL will only bear up to a total of VND350 million per year for the costs not
covered by the insurer, however, in 2021 TL decided not to seek any reimbursement from
the directors.
(5) In 2021, TL purchased some hi-tech equipment and shortened its useful life from five
years (as stipulated in Circular 45/2013 on depreciation) to three years. The depreciation
charge for this equipment in the 2021 financial statements was VND600 million.
(6) In December 2020, TL obtained a loan from a bank specifically to finance a new
investment to set up a new company in Cambodia. In 2021, the interest incurred on this
loan amounted to VND3,600 million.
The capital contributions to TL by its shareholders have been made in full.
(7) In 2021, TL incurred the following foreign exchange gains/losses, all of which had
been recorded in the 2021 audited income statement:
– a realised net gain of VND800 million;
– an unrealised loss on receivables as at 31 December 2021 of VND1,350 million;
– an unrealised gain on payables as at 31 December 2021 of VND1,280 million; and
– an unrealised gain on cash at bank as at 31 December 2021 of VND400 million.
Required:
Calculate TL JSC’s taxable income and tax liabilities (in VND millions) for corporate
income tax (CIT) purposes for the year ended 31 December 2021.
Note: You should list all of the items specifically referred to in notes 1 to 7, indicating by
the use of ‘0’ any item for which no adjustment is required.
Ex-change rate 23,500 VND for 1 USD
(Total: 15 marks)
6.
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(a) For the purposes of part (a) of this question you should assume that today’s date is 31
December 2021.
Mr Tom, who is 48 years old, and a US citizen, was assigned to work in his company’s
subsidiary in Vietnam, MCS Vietnam Co (MCS-V), from 1 January 2021. His wife,
Julian, who is 40 years old, followed him to Vietnam as a housewife without income. The
couple have two children, Jennifer aged 19 years (earning USD 1,000 in 2021 from the
sales of her painting) and Lewis aged 15 years. Lewis joined his parents in Vietnam, but
Jennifer continued her college education in the US.
Tom’s remuneration with MCS-V in 2021 consisted of the following:
– Annual salary: USD360,000 for the 12-month period.
– Performance bonus: one month’s salary plus USD35,000 performance incentives.
– Housing: MCS-V rented a house for Tom and his family for USD4,500 per month and
paid the rent directly to the landlord.
– Tuition fees: MCS-V reimbursed Tom for the university tuition fees for Jennifer in the
US of USD20,000 and the school fees for Lewis in Vietnam of USD15,000.
– Air fares: MCS-V reimbursed air fares for two round trips back to the US for Tom and
his wife. According to MCS-V’s records, the air fare cost for one round trip is USD3,000
per person.
– Medical insurance: MCS-V purchased medical insurance for each member of Tom’s
family who were present in Vietnam at a cost of USD2,000 per month per person.
– Car: MCS-V hired a car with a driver at a cost of VND20 million per month to
transport Tom between his house and the office.
– Accumulation insurance: MCS-V purchased an accumulation insurance for Tom with a
Manulife at a cost of USD3,000 per month. The cumulative contributions plus 6% per
year will be paid to Tom either on the five-year anniversary of the commencement of the
policy, or one year from the termination of his employment with MCS-V, whichever
comes earlier.
Required:
(i) Calculate Mr Tom’s taxable income and non-taxable income (before any housing
benefits) for the year 2021. (9 marks)
(ii) Calculate Mr Tom’s personal income tax (PIT) liability from employment for the year
2021. (4 marks)

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Note: All calculations should be made in VND millions, rounded to zero decimal in every
calculation.
(b) You should treat this part as independent of the calculations in part (a).
On 1 January 2021, Tom was granted options to purchase 1.2 million shares of MCS
Vietnam Co’s parent company, MCS US Inc, at USD1 per share. The options will
become vested to him at various dates over the next four years, provided that he
continues to be employed by the MCS group of companies. Options for the right to
purchase 300,000 shares at USD1 became vested on 31 December 2021, when the market
price was USD1.50 per share. Tom exercised the option to purchase these vested shares
on 2 January 2022 when the market price was USD1.52 per share.
Required:
Explain the personal income tax (PIT) treatment in Vietnam of the options granted to and
exercised by Mr Tom in the year 2021. (2 marks)
Ex-change rate VND 23,500 to USD 1
(Total: 15 marks)

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TAXATION (VNM) – MOCK TEST

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VND million VND million

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