Value-added tax (“VAT”) rate applicable to services provided to enterprises within non-tariff zones

On July 24, 2025, the Department of Management and Supervision on tax, fee and charge policy  issued Official Letter No. 1292/CST-GTGT providing guidance on the VAT rate applicable to services rendered to enterprises within non-tariff zones.  

Accordingly, services such as auditing, tax advisory, M&A consultancy, management consulting, etc. – in case are directly provided to organizations in non-tariff zones, consumed within the zones, serve export production activities and do not serve any other non-export activities, not among the services ineligible for the 0% VAT rate - shall be subject to the 0% VAT rate. 

Under Clause 1, Article 9 of the Law on VAT No. 48/2024/QH15 and Clause 2, Article 17 of Decree No. 181/2025/ND-CP, services provided to entities within non-tariff zones are considered export services and are eligible for the 0% VAT rate, provided that the following criteria are met: 

• The services are supplied directly to organizations operating within non-tariff zones; and 
• The services are consumed within the non-tariff zones and directly serve export production activities. 

In addition, Clause 5, Article 17 of Decree No. 181/2025/ND-CP further clarifies that such services must also: 

• Not serve any activities other than export production; and 
• Not fall under the categories of services excluded from the 0% VAT rate, as specified in Clause 4, Article 17 of Decree No. 181/2025/ND-CP.