Subjects of application

1. A organization that manufactures and/or sells goods/services (hereinafter referred to as taxpayers) that pays tax under the Law on Corporate income tax and makes tax statements using the method in Clause 1 Article 11 of the Law on Corporate income tax No. 14/2008/QH12 (corporate income tax payable equals assessable income multiplied by tax rate), makes business transactions with related parties, and submits an APA application before stating and paying tax on the first year of the period covered by the APA (hereinafter referred to as covered period).

The taxpayers are the entities covered by the APA mentioned in Clause 3 Article 3 of this Circular.

2. Tax administrations: the General Department of Taxation, Departments of Taxations of provinces.

3. State agencies, organizations and individuals related to the application of APA to tax management.

This Circular takes effect on February 05, 2014.