Mr. N.V.H reflected that on November 14, 2025, the Ministry of Finance issued Circular No. 108/2025/TT-BTC, but the Circular does not guide the compilation of reports for merged units.
In fact, as of June 30, 2025, many units have completed mergers and prepared finalization reports and financial statements, generating revenue and expenses in the reports.
Mr. H asked, when summarizing reports according to Circular No. 108/2025/TT-BTC, does the higher-level unit have to summarize the financial statements of the merged units to fully reflect revenue and expenses in the summary report?
Regarding this issue, the Ministry of Finance has the following opinions:
Regarding the higher-level accounting unit summarizing the financial statements of merged units according to the provisions of Circular No. 108/2025/TT-BTC dated November 14, 2025 of the Minister of Finance guiding the preparation of consolidated financial statements of administrative and non-business accounting units:
At point a, clause 2.1, Article 2, section I, Appendix 01, Official Dispatch No. 1010/BTC-QLKT dated January 23, 2025 of the Ministry of Finance guiding accounting work when organizing the implementation of arrangement and streamlining of the organizational apparatus, it is stipulated:
All economic and financial nghiep vu incurred by the underlying accounting unit in the final accounting period, including nghiep vu related to asset and financial handling before handing over to another unit, must be fully accounted for in the unit's accounting book before the closing of the final accounting book according to the provisions of the current Administrative and Commercial Accounting Regime and relevant guidance.
The underlying accounting unit subject to arrangement will prepare financial statements and finalization reports for operating expenses for the final accounting period to serve the handover".
Based on the above regulations, the merged accounting unit will have to close the accounting book, prepare financial statements and financial statements for the final accounting period (for example, the accounting period from January 1, 2025 to the end of June 30, 2025) and hand them over to the merger unit.
Accordingly, all revenue and expenses of the merged accounting unit must be transferred to determine the operating results in the period of the merged accounting unit according to the administrative and non-business accounting regime and hand over data to the receiving unit according to regulations. When handing over, all revenue and expense accounts of the merged accounting unit must have expired balances.
According to point b, clause 1, Article 20 of Circular No. 108/2025/TT-BTC:
In 2025, there is a merger of units (still maintaining the operations of the old accounting unit from January 1, 2025 and merging additional operations of other accounting units), then the financial statements for 2025 of the post-merger accounting unit are prepared for the accounting period from January 1, 2025 to the end of December 31, 2025, the unit must clearly explain the changes in operational scale, data received in 2025. The financial statements for 2025 of the post-merger accounting unit (with larger scale) still have the number of beginning period, number of previous years inherited from the pre-merger accounting unit".
Based on Clause 2, Article 20 of Circular No. 108/2025/TT-BTC stipulating:
For higher-level accounting units preparing consolidated financial statements, in 2025, there are divisions, mergers, and consolidations, then the consolidated financial statements for 2025 are consolidated data from the financial statements of existing affiliated accounting units at the end of the 2025 accounting period (December 31, 2025) and the unit must clearly explain this matter".
Based on the above regulations, higher-level accounting units only consolidate financial statement data of existing affiliated accounting units at the end of the 2025 accounting period (December 31, 2025), and at the same time, higher-level accounting units must clearly explain the division, merger, and consolidation on the consolidated financial statements explanation.
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