Taxation – Vietnam

(VNM)(F6) Syllabus rationale

June & December 2017 This is a narrative explaining how the syllabus is
structured and how the main capabilities are linked.
This syllabus and study guide is designed to help The rationale also explains in further detail what the
with planning study and to provide detailed examination intends to assess and why.
information on what could be assessed in
any examination session. Detailed syllabus

THE STRUCTURE OF THE SYLLABUS AND This shows the breakdown of the main capabilities
STUDY GUIDE (sections) of the syllabus into subject areas. This is
the blueprint for the detailed study guide.
Relational diagram of paper with other papers
Approach to examining the syllabus
This diagram shows direct and indirect links
between this paper and other papers preceding or This section briefly explains the structure of the
following it. Some papers are directly underpinned examination and how it is assessed.
by other papers such as Advanced Performance
Management by Performance Management. These Study Guide
links are shown as solid line arrows. Other papers
only have indirect relationships with each other This is the main document that students, tuition
such as links existing between the accounting and providers and publishers should use as the basis of
auditing papers. The links between these are shown their studies, instruction and materials.
as dotted line arrows. This diagram indicates where Examinations will be based on the detail of the
you are expected to have underpinning knowledge study guide which comprehensively identifies what
and where it would be useful to review previous could be assessed in any examination session.
learning before undertaking study. The study guide is a precise reflection and
breakdown of the syllabus. It is divided into sections
Overall aim of the syllabus based on the main capabilities identified in the
syllabus. These sections are divided into subject
This explains briefly the overall objective of the areas which relate to the sub-capabilities included
paper and indicates in the broadest sense the in the detailed syllabus. Subject areas are broken
capabilities to be developed within the paper. down into sub-headings which describe the detailed
outcomes that could be assessed in examinations.
Main capabilities These outcomes are described using verbs
indicating what exams may require students to
This paper’s aim is broken down into several main demonstrate, and the broad intellectual level at
capabilities which divide the syllabus and study which these may need to be demonstrated
guide into discrete sections. (*see intellectual levels below).

Relational diagram of the main capabilities INTELLECTUAL LEVELS

This diagram illustrates the flows and links between The syllabus is designed to progressively broaden
the main capabilities (sections) of the syllabus and and deepen the knowledge, skills and professional
should be used as an aid to planning teaching and values demonstrated by the student on their way
learning in a structured way. through the qualification.

The specific capabilities within the detailed

syllabuses and study guides are assessed at one of
three intellectual or cognitive levels:

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 Level 1: Knowledge and comprehension subject area headings depending on the nature of
Level 2: Application and analysis the subject and how these areas have been broken
Level 3: Synthesis and evaluation down.

Very broadly, these intellectual levels relate to the GUIDE TO EXAM STRUCTURE
three cognitive levels at which the Knowledge
module, the Skills module and the Professional level The structure of examinations varies within and
are assessed. between modules and levels.

Each subject area in the detailed study guide The Fundamentals level examinations contain
included in this document is given a 1, 2, or 100% compulsory questions to encourage
3 superscript, denoting intellectual level, marked at candidates to study across the breadth of each
the end of each relevant line. This gives an syllabus.
indication of the intellectual depth at which an area
could be assessed within the examination. However, The Knowledge module is assessed by equivalent
while level 1 broadly equates with the Knowledge two-hour paper based and computer based
module, level 2 equates to the Skills module and examinations.
level 3 to the Professional level, some lower level
skills can continue to be assessed as the student The Skills module examinations F5-F9 are all paper
progresses through each module and level. This based exams containing a mix of objective and
reflects that at each stage of study there will be a longer type questions with a duration of three hours
requirement to broaden, as well as deepen 15 minutes. The Corporate and Business
capabilities. It is also possible that occasionally Law (F4) paper is a two-hour objective
some higher level capabilities may be assessed at test examination which is also available as a
lower levels. computer based exam for English and Global
variants, as well as paper based for all variants.
LEARNING HOURS AND EDUCATION
RECOGNITION The Professional level papers are all of three-hour
15 minutes duration and all contain two
The ACCA qualification does not prescribe or sections. Section A is compulsory, but there will be
recommend any particular number of learning hours some choice offered in Section B.
for examinations because study and learning
patterns and styles vary greatly between people and ACCA has removed the restriction relating to reading
organisations. This also recognises the wide and planning time, so that while the time
diversity of personal, professional and educational considered necessary to complete these exams
circumstances in which ACCA students find remains at 3 hours, candidates may use the
additional 15 minutes as they choose. ACCA
themselves.
encourages students to take time to read questions
carefully and to plan answers but once the exam
As a member of the International Federation of time has started, there are no additional restrictions
Accountants, ACCA seeks to enhance the education as to when candidates may start writing in their
recognition of its qualification on both national and answer books.
international education frameworks, and with
educational authorities and partners globally. In Time should be taken to ensure that all the
doing so, ACCA aims to ensure that its qualifications information and exam requirements are properly
are recognized and valued by governments, read and understood.
regulatory authorities and employers across all
sectors. To this end, ACCA qualifications are The Essentials module papers all have a Section A
currently recognized on the education frameworks in containing a major case study question with all
several countries. Please refer to your national requirements totalling 50 marks relating to this
education framework regulator for further case. Section B gives students a choice of two from
information. three 25 mark questions.

Each syllabus contains between 23 and 35 main

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Section A of both the P4 and P5 Options papers
contain one 50 mark compulsory question, and
Section B will offer a choice of two from three
questions each worth 25 marks each.

Section A of each of the P6 and P7 Options papers

contains 60 compulsory marks from two questions;
question 1 attracting 35 marks, and question 2
attracting 25 marks. Section B of both these
Options papers will offer a choice of two from three
questions, with each question attracting 20 marks.

All Professional level exams contain four

professional marks.

The pass mark for all ACCA Qualification

examination papers is 50%.

GUIDE TO EXAMINATION ASSESSMENT

ACCA reserves the right to examine anything

contained within the study guide at any examination
session. This includes knowledge, techniques,
principles, theories, and concepts as specified.

For the tax papers, ACCA will publish examinable

documents, or tax rates and allowances tables, once
a year to indicate exactly what legislation could
potentially be assessed within identified
examination sessions. These should be read in
conjunction with the information below.

For VNM tax papers, June and December

examinations will be based on legislation passed
before the previous 31 December. I.e. June and
December 2017 papers will be based on legislation
passed by 31 December 2016.

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 Syllabus MAIN CAPABILITIES

After completing this examination paper students

should be able to:

A Explain the operation and scope of the

F6 VNM Vietnamese tax system and the obligations of
tax payers and the implications of non-
compliance

B Explain and compute the personal income tax

liabilities of individuals

C Explain and compute the corporate income tax

AIM liabilities of both domestic and foreign owned
companies
To develop knowledge and skills relating to the tax
system as applicable to individuals and businesses D Explain and compute the tax liabilities arising
(domestic and foreign owned) operating in Vietnam. under the regime applicable to foreign
contractors

E Explain and compute the effects of value added

tax on businesses

RELATIONAL DIAGRAM OF MAIN CAPABILITIES

The Vietnamese tax system and its administration (A)

Personal income tax (B) Corporate income tax (C)

Foreign contractor tax (D) VAT (E)

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RATIONALE 3. The comprehensive computation of monthly
and annual taxable income and tax liabilities
This syllabus introduces candidates to the subject of
taxation and provides the core knowledge of the 4. The use of exemptions and reliefs in deferring
underlying principles and major technical areas of and minimising PIT liabilities
taxation, as they affect the activities of individuals
and businesses. C Corporate income tax

In this syllabus, candidates are introduced to the 1. The scope of corporate income tax (CIT)
rationale behind and the functions of the tax
system. The syllabus then considers the separate 2. Profits subject to CIT
taxes that an accountant would need to have a
detailed knowledge of, such as personal income tax; 3. The comprehensive computation of CIT
corporate income tax; foreign contractor tax; and liabilities
value added tax.
4. The use of tax exemptions and reliefs in
Having covered the core areas of the basic taxes, deferring and minimising CIT liabilities
the candidate should be able to compute tax
liabilities, explain the basis of their calculations, D Taxation of foreign contractors
apply tax planning techniques for individuals and
companies and identify the compliance issues for 1. The scope of the foreign contractor tax (FCT)
each major tax through a variety of business and regime
personal scenarios and situations.
2. The computation of FCT liabilities
DETAILED SYLLABUS
E Value added tax
A The Vietnamese tax system and its
administration 1. The scope of value added tax (VAT)

1. The overall function and purpose of taxation in 2. Bases and methods of calculation
a modern economy

2. Overall structure of Vietnamese tax system

3. The systems of registration and the making of

returns

4. The submission of information and claims and

the payment of tax liabilities

5. Transfer pricing

6. The procedures relating to enquiries, appeals

and disputes

7. Penalties for non-compliance

B Personal income tax

1. The scope of personal income tax (PIT)

2. Income subject to PIT

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 APPROACH TO EXAMINING THE SYLLABUS

The syllabus is assessed by a three-hour 15 minute

paper-based examination.

The paper will be predominantly computational and

all questions are compulsory.

Section A of the exam comprises 15 multiple choice

questions of 2 marks each.

Section B of the exam comprises four 10 mark

questions and two 15 mark questions.

The two 15 mark questions will focus on income tax

(syllabus area B) and corporate income tax (syllabus
area C).

The section A questions and the other questions in

section B can cover any areas of the syllabus.

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Study Guide 4. The submission of information and claims and
the payment of tax liabilities

A THE VIETNAMESE TAX SYSTEM AND ITS a) Describe the procedures by which registered
ADMINISTRATION taxpayers pay and finalise their liabilities.[2]

1. The overall function and purpose of taxation in b) Explain the provisional tax payment system,
a modern economy including the methods of calculation,
amendment, payment dates and system of
a) Describe the purpose (economic, social etc) of credits, taking into account the provisional VAT
taxation in a modern economy.[2] and CIT payment requirements for
geographically dispersed businesses
b) Identify the different types of taxes.[1] operations.[2]

c) Explain the difference between direct and c) Describe the procedures for the periodic
indirect taxation.[2] deduction and payment of taxes, clearly
distinguishing the responsibilities of each of the
2. Overall structure of Vietnamese tax system following:
- bodies paying income;
a) Describe the overall structure of the - taxpayers; and
Vietnamese tax system.[1] - the tax authorities.[2]

b) Explain the difference between tax avoidance d) Describe the procedures for tax finalisation
and tax evasion.[1] in the case of tax payers.[2]

c) Explain the need for an ethical and professional e) Explain how relief is given in respect of
approach.[2] taxpayer error.[1]

Excluded topics f) Describe the procedures by which eligible

taxpayers may apply for a tax refund or
• Law on Investment credit.[1]
• Enterprise Law
• Intellectual property and technology transfer 5. Transfer pricing
regulations (except as detailed in the Study
Guide)
a) Explain and apply the transfer pricing rules
• Anti avoidance legislation (except as detailed
in the Study Guide) (including concepts such as “arm’s length
price”, “transactions between related parties”,
3. The systems of registration and the making of “independent transactions”) and prepare
returns relevant calculations. [2]

a) Describe the procedures by which individuals b) State when companies are ‘affiliated’ (a.k.a.
and organisations register with the tax ‘related’) and the rights and responsibilities
authorities.[1] (especially disclosure responsibilities) of
taxpayers who have transactions with affiliated
b) Describe the procedures by which registered parties.[1]
taxpayers submit returns and declare and
amend their tax liabilities.[1] c) Explain the powers of the tax office to
determine income according to market prices
[1]
c) Explain the obligation of businesses to keep
proper books of account and the consequences
of failing to do so.[1] d) Describe the methodologies used to determine
market price.[1]

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 6. The procedures relating to enquiries, appeals d) Explain how the attribution of income is
and disputes determined.[2]

a) Explain the rights and obligations of taxpayers e) Explain how the income of individuals in the
with respect to tax complaints.[1] capacity of producers, traders and service
providers is determined.[2]
b) Explain the duties, powers and responsibilities
of the tax authorities with regard to tax f) Explain the treatment of business income,
declarations, the calculation, assessment and salary income, income from capital
collection/recovery of tax due, tax complaints investments, income from capital transfers,
and tax audit.[1] income from real property transfers, income
from winnings or prizes, royalty income,
7. Penalties for non-compliance income from franchises, income from
inheritances, income from receipt of a gift and
a) State the penalties for non-compliance, under- other income.[2]
declaration and late tax payment.[1]
Excluded topics
B PERSONAL INCOME TAX
• Agricultural income of small scale
1. The scope of personal income tax (PIT) producers

a) Identify the individuals, resident and non- 3. The comprehensive computation of monthly
resident, liable to pay PIT.[2] and annual taxable income and tax liabilities

b) Explain how the tax residence of an individual a) Compute business and salary income,
is determined.[2] including the assessment of employment
benefits in kind.[2]
c) Recognise the difference in the tax treatment of
a resident individual and a non-resident b) Compute other taxable income and distinguish
individual.[2] its treatment from that of business and salary
income.[2]
d) Recognise the difference in the tax treatment of
income sourced from Vietnam or outside of c) State the expenses and apply the deductions (if
Vietnam for residents and non-residents.[2] any) that can be used to reduce taxable
income.[2]
e) Understand how a double taxation agreement
can affect the liability to taxation of certain d) Recognise the individual income of non-
classes of individual and of different types of resident subject to personal income tax and
income.[2] compute the tax to be withheld.[2]

2. Income subject to PIT e) Compute the monthly and annual tax liabilities
of residents and non-residents with regard to:
a) Explain the basis of assessment for income - all types of income whether sourced from
derived by an individual.[2] Vietnam or overseas.[2]

b) Identify exempt income, allowances, benefits f) Compute any available tax credit and double
and receipts not subject to PIT and reductions taxation relief in respect of foreign taxes and
in tax.[2] withholding taxes.[2]

c) Distinguish between income which is subject

to progressive PIT rates and income which is
subject to specific PIT rates.[2]

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4. The use of exemptions and reliefs in deferring d) Recognise and compute ‘deductible
and minimising PIT liabilities expenses’.[2]

a) Identify, compute and apply the right e) Recognise the items that do not constitute
reduction/relief in given circumstances.[2] deductible expenses.[2]

b) Explain how alternative structuring of all types f) Explain and compute the ‘other income’ that
of income can result in different amounts of should be included in taxable income.[2]
taxable income and tax liability.[2]
g) Depreciation and amortisation of assets
Excluded topics i) State the conditions that must be satisfied
for depreciation of a fixed asset to be
• Detailed provisions of individual tax treaties included in deductible expenses [1]
ii) Explain the types of qualified fixed assets
C CORPORATE INCOME TAX (for depreciation) and compute the eligible
cost of tangible fixed assets, intangible fixed
1. The scope of corporate income tax assets and leased assets [2]
iii) Compute the allowable depreciation
a) Explain and apply the territorial scope of expense in accordance with Ministry of
corporate income taxation in Vietnam.[2] Finance decisions [2]
iv) Distinguish between repairs and
b) Identify the business establishments liable to improvements and determine the effect of
CIT.[2] improvements on the calculation of
depreciation [2]
c) Explain how the tax residence of a company is v) Explain the treatment of a disposal or part
determined.[2] disposal of depreciable assets.[2]

d) Understand how a double taxation agreement h) Capital Assignments and Transfer of securities
can affect the liability to taxation of different and projects
types of income.[2] i) Explain the treatment of transfers of
projects, shares, bonds and other securities
e) Understand how companies and institutions in by business enterprises [2]
certain specific industries (e.g. securities, ii) Explain and apply the reliefs available to an
banking, real estate etc.) are taxed.[2] investor transferring the whole or part of
their capital investment to a third party.[2]
Excluded topics
i) Taxation of Real Property Transfers
• Tax Exempt Income as defined by the Law on i) Explain the circumstances in which the
CIT. transfer of real property is liable to
corporate income tax [2]
2. Profits subject to CIT ii) Compute the taxable income (turnover less
expenses) on the transfer of real property.[2]
a) Explain the basis of assessment for CIT,
including on the commencement and cessation j) Losses and carry forward losses
of an enterprise.[2] i) Explain and apply the relief available for
losses against income in the year of loss
b) Define the terms ‘assessable income’, ‘taxable (current year) and in subsequent years [2]
income’ and ‘tax assessment period’.[1]
k) Welfare expenses
c) Explain ‘taxable revenue’ and reduction to i) State the types of deductible welfare
taxable revenue for enterprises in specific expenses, distinguish with other categories
industries.[2] of expenses and the conditions for
additional deduction of welfare expenses[2]

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 ii) Calculate the deductible welfare expenses iii) Double taxation relief
(taking into account the cap) [2] - Explain and apply the available forms of
double taxation relief:
l) Science and Technology Funds - treaty relief (of DTAs as provided); and
i) State how the additional deduction operates - unilateral tax credit relief [2]
ii) Calculate the tax arrears and other amounts - Compute the double taxation relief
payable for cases of non-compliance.[2] available in respect of foreign withholding
and underlying taxes.[2]
m) Provisions for doubtful debts, investments,
inventory, warranty and severance allowance Excluded topics
i) Describe tax treatments of these provisions.
ii) Calculate the tax implications from these • Detailed lists of provinces or geographical
provisions. [2] locations etc for the purposes of tax
incentives
n) Understand the implications of capital versus • Detailed provisions of individual tax treaties
debt financing in the case of foreign invested
enterprises and compute relevant amounts.[2] 4. The use of exemptions and reliefs in deferring
and minimising CIT liabilities
3. The comprehensive computation of CIT
liabilities a) Identify, compute and apply the right
reduction/relief and tax saving/deferral
a) Prepare a CIT computation, including the arrangement in given circumstances.[2]
standard CIT declaration forms, taking into
account the tax regulations.[2] D TAXATION OF FOREIGN CONTRACTORS

b) Compute the CIT liability at non-reduced 1. The scope of the foreign contractor tax (FCT)
rates.[2] regime

c) Tax incentive exemptions and reductions a) Identify applicable and non-applicable

i) Describe the general application of CIT subjects/transactions.[2]
incentives applicable to investment projects
under the tax regulations [1] b) Explain the inter-relationship between the FCT
ii) Explain the general qualifying conditions regime and CIT, VAT and PIT.[2]
that must be satisfied, the nature of the
incentive and the duration of application in c) Define the terms ‘foreign contractor’; sub-
each case [1] contractor’; ‘income arising in Vietnam’;
iii) Compute the CIT liability at reduced rates Income from the transfer of ownership of or
(where applicable).[2] right to use assets; ‘royalty’; and ‘loan
interest’.[1]
d) Overseas aspects
i) Business structure, representative offices, Excluded topics
branch or subsidiary
- Define ‘permanent establishment’ [1] • Definition of intellectual property rights and
- Apply the concept of permanent technology transfer in accordance with the
establishment to determine the taxability of Civil Code
income in Vietnam [2]
- Explain and distinguish the CIT 2. The computation of FCT liabilities
implications of a representative office,
branch and subsidiary of a foreign a) Compute the VAT and CIT liabilities,
corporation [2] responsibilities for filing and payment for
ii) Recognise the circumstances in which foreign contractors adopting the Vietnamese
foreign income is regarded as having been accounting system (VAS) (i.e. the actual
received in Vietnam [2]

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 method) and simplified VAS (i.e. hybrid - tax credit; and
method).[2] - directly on the basis of added value.[2]

b) Compute the VAT and CIT liabilities, c) Explain and apply the time of supply rules.[2]
responsibilities for filing and payment for
foreign contractors not adopting the d) Determine the taxable revenue in specific
Vietnamese accounting system (VAS) (i.e. cases.[2]
deemed method).[2]
e) Explain the treatment of financial services,
c) Apply the double taxation relief provisions in including credit, securities trading, capital
the context of the FCT regime.[2] transfers and derivatives.[2]

E VALUE ADDED TAX f) Explain the treatment of free goods and

internally consumed goods.[2]
1. The scope of value added tax (VAT)
g) State the circumstances in which input VAT
a) Describe the scope of value added tax.[2] may be carried forward as a tax credit and/or
refunded.[1]
b) State who is and who is not a VAT taxpayer.[2]
h) Explain the categories and forms of VAT
c) Identify the taxable and non-taxable (exempt) invoices, the mandatory contents in VAT
objects.[2] invoices, and usage of VAT invoices (in
particular: requirements for issuance of
d) Understand the principal zero-rated supplies invoices, point of time for issuing invoices,
and supplies for which VAT calculation and handling invoices with errors, reporting usage
declaration is not required.[1] of invoices).

2. Bases and methods of tax calculation i) Explain the VAT invoicing treatments in special
cases, in particular: discounts / rebates, goods
a) Explain the principles that apply to the for promotional purposes, goods returned to
valuation of supplies and imports.[2] seller, invoices lost, transactions in disputes.[2]

b) Explain and apply the accepted methods of tax

calculation:

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 READING LIST

Vietnam Laws Online Database, Phillips Fox (English

Versions) (including: Decision 206, and Circular 60).

OECD Model Tax Convention on double taxation.

The study of relevant articles in the ACCA’s student
accountant magazine is also recommended.

Note: Whenever the word “regulations” is used, it refers

to the Law, Decrees and Circulars of the particular tax.

SUMMARY OF CHANGES TO F6 (VNM)

ACCA periodically reviews it qualification syllabuses so

that they fully meet the needs of stakeholders such as
employers, students, regulatory and advisory bodies and
learning providers.

There have been no changes to the syllabus for 2017.

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