Mr. L.T.T asked that Decree No. 103/2024/ND-CP and the draft amendments and supplements to this Decree currently have many shortcomings in the way of expression and wording, which can easily lead to being understood in many different meanings.
This situation can cause difficulties in the process of administrative procedures, forcing people to use intermediary services when handling documents.
According to Mr. T, referring to the second draft amendment to Decree No. 103/2024/ND-CP, which proposes to amend Clause 1, Article 17 with the content: "Households and individuals who are exempted from or have their land use fees reduced according to the provisions of Article 18 and Article 19 of this Decree are only exempted or have their land use fees reduced once for the land area within the land allocation limit when the State allocates land for housing or is allowed to change the land use purpose from other land to residential land or is recognized as residential land purpose according to the provisions of the law on land".
Mr. T said that the above content is still unclear, especially the concept of "limited when changing land use purpose".
Currently, the law does not have specific regulations on the limit when changing land use purposes, so this expression causes confusion not only for people but also for enforcement officers.
Therefore, he suggested that competent authorities promptly clarify the above content to ensure consistency in application and avoid problems in practice.
Regarding this issue, the Ministry of Finance has the following opinion:
Based on the opinions of ministries, branches, localities and related subjects, the Ministry of Finance has submitted to the Government to issue Decree No. 291/2025/ND-CP dated November 6, 2025 of the Government amending and supplementing a number of articles of Decree No. 103/2024/ND-CP dated July 30, 2024 of the Government regulating land use fees, land rents and Decree No. 104/2024/ND-CP dated July 31, 2024 of the Government regulating the Land Development Fund; including content related to amending and supplementing regulations on exemption of land use fees for people with revolutionary contributions.
Regarding Circular No. 80/2021/TT-BTC, the Ministry of Finance is currently drafting a Circular amending and supplementing Circular No. 80/2021/TT-BTC.
According to the 2024 Land Law and detailed implementing documents, there are only regulations on land allocation limits and recognition limits for land use rights; there are no regulations on " limits when changing land use purposes".
