Buying advertising on Meta (Facebook, Instagram): enterprises must withhold and pay VAT and CIT on Meta's behalf

On 20 October 2026, Ho Chi Minh City Grassroots Tax Office No. 2 issued Official Letter No. 13194/TCS2-QLDN2, responding to an enterprise's questions on tax registration, tax declaration, tax payment and deductible expenses when purchasing online advertising services from Meta Platforms Ireland Limited ("Meta"). The key point: an enterprise paying VAT under the input-credit method must itself withhold and pay VAT and corporate income tax (CIT) on behalf of Meta each time it makes a payment, even though Meta already holds a tax identification number in Vietnam.

1. Who must withhold and pay on Meta's behalf?

Enterprises paying VAT under the input-credit method. When purchasing advertising for which Meta does not charge or collect 10% VAT (the payment price excludes Vietnamese tax), the enterprise is responsible for withholding, declaring and paying on Meta's behalf both VAT and CIT (Article 9 of Circular No. 69/2025/TT-BTC; Article 7 of Circular No. 20/2026/TT-BTC). This must be done at the time of payment to Meta, in accordance with Clause 3, Article 43 and Clause 1, Article 44 of Decree No. 252/2026/ND-CP (effective from 1 July 2026). Meta is not required to declare and pay tax on the portion of revenue for which tax has been withheld and paid by the Vietnamese party (Clause 3, Article 43 of Decree 252/2026/ND-CP).

Meta's tax identification number does not replace the withholding obligation. Meta has been granted a tax identification number in Vietnam (9000000327) so that it can directly declare and pay tax on revenue for which tax has not been withheld and paid by a Vietnamese party - for example, revenue from individuals or from organizations not applying the input-credit method.

Enterprises paying VAT under the direct method are not subject to withholding and paying on behalf under Clause 3, Article 43 of Decree 252/2026/ND-CP. In that case, the obligation to declare and pay tax rests with Meta.

2. Registering a tax identification number for withholding

• A separate withholding tax identification number is required (10 digits). The enterprise may not use its existing tax identification number to declare and pay tax on Meta's behalf.
• Dossier: Tax Registration Declaration Form No. 04.1-ĐKT, together with the List of foreign contractor and foreign subcontractor contracts paying tax through the Vietnamese party, Form No. BK04.1-ĐKT, in accordance with Clause 5, Article 7 of Circular No. 90/2026/TT-BTC.
• Deadline: no later than 10 working days from the date of the first payment or income payment to the overseas supplier, applicable where no direct contract has been signed (Point c, Clause 3, Article 6 of Decree 252/2026/ND-CP).

3. Declaring and paying tax on behalf

• Tax return: Form No. 01/NTNN, NCCNN in Appendix I of Circular No. 89/2026/TT-BTC. On the return, the enterprise ticks the box for business organizations in Vietnam applying the input-credit method that withhold and pay tax on behalf of overseas suppliers, and records Meta's Vietnamese tax identification number (9000000327).
• Deadline for submitting the tax return (Article 10 of Decree 252/2026/ND-CP; Article 30 of Circular 89/2026/TT-BTC):
  • Declaration per payment: no later than the 10th day from the date of payment to Meta;
  • Monthly declaration (where there are multiple payments in a month): no later than the 20th day of the following month;
  • For taxes declared quarterly: no later than the last day of the first month of the quarter following the quarter in which the tax obligation arises.
• Tax payment deadline: no later than the last day of the deadline for submitting the tax return.

4. No paper contract: use electronic records

Where the enterprise has not signed a direct paper contract with Meta and transacts electronically, it may use the following electronic records and data as the basis for determining its tax obligations:

• Meta's Terms of Service;
• Payment receipts / e-invoices (Receipt/Invoice);
• Transaction history on the advertising account;
• Non-cash payment documents via bank.

The enterprise must keep these records on file and present them upon request by the tax authority (under Circular 89/2026/TT-BTC).

5. Input VAT credit

For enterprises paying tax under the input-credit method, the document evidencing payment to the State Budget of VAT paid on Meta's behalf is the very document used to claim input VAT credit, provided two conditions are met: the service is used for VAT-taxable production and business activities, and there are valid non-cash payment documents (Points a and b, Clause 2, Article 14 of the Law on Value-Added Tax No. 48/2024/QH15; Article 26 of Decree No. 181/2025/ND-CP).

6. Deductible expenses for CIT purposes

The Official Letter distinguishes two cases in which VAT paid on behalf is not creditable:

General conditions for an expense to be deductible (Clause 1, Article 9 of Decree 320/2025/ND-CP): (a) it is actually incurred and related to production and business activities; (b) it is supported by adequate invoices and documents as prescribed; (c) it is supported by non-cash payment documents for each payment of VND 5 million or more.

Documentation package the enterprise should prepare:

1. The Terms of Service and the enterprise's advertising account information on the Meta platform;
2. Payment receipts / e-invoices issued by Meta, together with ad-run data and history demonstrating that the services serve the enterprise's business activities;
3. Valid non-cash payment documents for payments to Meta. Note: payments should be made with a debit or credit card in the company's name. In practice, some enterprises run ads using a personal credit card and then pay the tax on Meta's behalf; in such cases, there is a risk that the expense is regarded as inappropriate and is not deductible for CIT purposes;
4. Tax return Form No. 01/NTNN, NCCNN and the document evidencing payment of the withheld tax to the State Budget.

7. Accounting treatment

For VAT paid on behalf that is not creditable, the enterprise should account for it in accordance with the prevailing accounting standards and the enterprise accounting regime it applies. The Official Letter does not provide specific accounting entries.

💡 Recommendations for enterprises

1. Confirm which VAT calculation method you apply to determine whether you are subject to withholding and paying on behalf.
2. If you have paid Meta since 1 July 2026 without registering a withholding tax identification number, register immediately and review the tax periods already incurred.
3. Choose monthly declaration if you pay for advertising several times a month, to reduce the number of filings.
4. Pay with a corporate card or corporate account, not a personal card, to preserve eligibility for VAT credit and expense deductibility.
5. Regularly download and keep receipts and ad-run history from your Meta account, as these serve in place of a contract.

View Official Letter No. 13194/TCS2-QLDN2

This newsletter is prepared by Crowe Vietnam for general information purposes only and does not constitute advice for any specific case. Enterprises should refer to the original legal instruments and consult professional advisors before applying the above to their particular circumstances.