Recently, reader N.X.H - representative of a specialized project management board (public non-business unit) sent questions to functional agencies about the obstacles in the investment capital finalization process.
According to reports, Mr. H.'s unit performs the function of project management consulting and construction supervision. This unit registers to pay Value Added Tax (VAT) by direct method (percentage% on revenue). When signing contracts with investors, the contract value includes VAT according to the estimate approved by competent authorities.
However, trouble arose at the final stage. "When submitting the investment capital finalization report, the Department of Finance did not accept the 10% VAT cost in the total contract value and requested to cut and not approve this cost in the finalization value for consulting packages," Mr. H. angrily shared and questioned the legality of this decision.
To answer this question, the Ministry of Finance has cited the latest regulations in Circular 69/2025/TT-BTC and Decree No. 181/2025/ND-CP (effective from July 1, 2025).
Accordingly, for units paying taxes by direct method, the VAT amount to be paid is calculated as a percentage of% multiplied by revenue. Revenue here is the total amount of sales of goods and services recorded on the invoice (including surcharges).
Most importantly, the % ratio is not an arbitrary or default figure of 10% as in the deduction method. Specifically, Appendix I issued together with Circular 69/2025/TT-BTC clearly stipulates: The group of consulting, design, and construction supervision services basically applies a VAT calculation rate of 5%.
Thus, the unit's calculation of VAT costs of 10% in the dossier while being subject to direct tax payment (with a set level of 5% for this field) is not in accordance with current regulations. The financial agency has a basis to review this cost level when finalizing.
