Official Letter No. 1105CT-CS dated 09 May 2025, from the Tax Department regarding tax policies applicable to brokerage commission expenses

Regarding Corporate Income Tax (CIT) policy

In principle, enterprises are allowed to deduct expenses when calculating CIT if the following conditions are met:

  • The expenses actually arise and are related to the enterprise’s production and business activities;
  • The expenses are supported by valid invoices and documents in accordance with legal regulations;
  • For expenses involving invoices for the purchase of goods or services with a value of VND 20 million or more per transaction (VAT included), payment must be made via non-cash methods with proper supporting payment documents.

For foreign organizations and individuals providing brokerage services—such as selling goods or supplying services to Vietnamese organizations or individuals—if such services are performed abroad, they are not subject to foreign contractor tax as stipulated in Clause 4, Article 2 of Circular No. 103/2014/TT-BTC.

In the case where the Company incurs brokerage commission expenses, if these expenses meet the conditions for deductible expenses and are not classified as non-deductible under the CIT regulations, the Company is allowed to include such brokerage commission expenses as deductible when calculating Corporate Income Tax.

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