💼 [NEW GUIDANCE] VAT DECLARATION & PAYMENT FOR EXPORT PROCESSING ENTERPRISES (EPEs)

Export Processing Enterprises (EPEs) often wonder:
Do we have to declare Value-Added Tax (VAT)? And in which cases?
The Hung Yen Tax Department has provided clear and official guidance as follows:

✅ 1. When EPEs are NOT required to declare VAT

  • ✔ EPEs are NOT required to declare or pay VAT for processing/manufacturing activities for export.

👉 These are considered non-tariff zone activities, and therefore not subject to VAT declaration.

✅ 2. When EPEs MUST declare and pay VAT

EPEs must declare VAT when they engage in any business activities outside the scope of export processing.

Examples include:

  • • Purchasing goods from the domestic market for export (right to export).
  • • Importing goods and selling them into the domestic market (right to import).
  • • Other commercial transactions not considered export processing activities.

📌 3. Conditions for VAT declaration on non-export activities

🔹 Separate accounting

EPEs must separately record:

  • Goods – revenue – expenses for export processing activities
  • Goods – revenue – expenses for non-export activities

🔹 Tax registration with the domestic tax authority

To declare VAT for non-export activities, EPEs must register for tax with the competent local tax office.

🔹 Separate storage areas

Storage areas for export-processing goods must be clearly separated from areas used for
other business activities (sales into the domestic market, import/export rights…).

📅 4. VAT declaration period

🔸 Monthly declaration

Under Point a, Clause 1, Article 8 of Decree 126/2020/ND-CP,
monthly VAT declaration is the default requirement for EPEs.

🔸 Quarterly declaration

If the EPE’s total revenue in the preceding year ≤ VND 50 billion,
it is eligible to declare VAT quarterly
(Point a, Clause 1, Article 9 of Decree 126/2020/ND-CP).

🧾 5. Invoice usage

  • • Under the credit method → use VAT invoices.
  • • Under the direct method → use sales invoices.
  • • When selling into the domestic market or non-tariff zones, invoices must state:

    👉 “For organizations and individuals in non-tariff zones.”

🎯 SUMMARY – EPEs DECLARE VAT ONLY WHEN:

  • ✔ They conduct commercial activities beyond export processing.
  • ✔ They perform separate accounting and have proper tax registration.
  • ✔ They apply the correct monthly or quarterly declaration period.
  • ✔ They use the correct invoice type according to their VAT method.

📩 Need MBA Audit to review your EPE vs. non-EPE model, separate accounting, or import–export–inventory documentation?

We are always ready to support your business. 💚

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