The meeting was chaired by Dr. Nguyen Quoc Hung, Vice Chairman cum General Secretary of VNBA. Attending the meeting were representatives of the Department of Finance and Accounting, the Department of Credit for Economic Sectors under the State Bank of Vietnam, and representatives of CIs that are VNBA members.
In his opening speech, Dr. Nguyen Quoc Hung emphasized the importance of the 2024 VAT Law, Decree No. 181/2025/ND-CP and Circular No. 69/2025/TT-BTC, affirming that these are legal documents that have a direct and profound impact on business activities as well as tax obligations of the entire banking system. However, VNBA has received many feedbacks from member credit institutions about difficulties and obstacles in the implementation process. Therefore, the meeting was held to unify recommendations, clarify each clause and content that is still problematic, and at the same time provide a full legal and practical basis for competent authorities to consider and adjust. The report summarizing difficulties from member credit institutions presented by the VNBA Legal & Professional Affairs Board pointed out a number of major issues, including:
• Legal conflicts on handling secured assets: Clause 9, Article 5 of the VAT Law 2024 stipulates that the sale of secured assets is subject to VAT, while the Law on Credit Institutions 2024 identifies this as a non-taxable activity.
• Inadequacies in tax declaration when selling real estate: Regulations in Circular No. 80/2021/TT-BTC require credit institutions to declare taxes at both the location of the real estate and at the head office, causing procedural complications, increasing compliance costs and potential risks of under-declaration or double-declaration.
• VAT on deposit certificates is still unclear.
• Lack of guidance on determining taxable revenue for valuable papers.
• Problems with credit service fees, how to determine deductible land prices to calculate VAT when transferring real estate, criteria for determining exported financial services to apply a 0% tax rate;
• Lack of consistency between Decree No. 181/2025/ND-CP and guiding Circulars.
At the meeting, representatives of credit institutions expressed concerns about legal risks arising from the current self-declaration and self-payment mechanism due to the lack of detailed and unified instructions. Banks recommended that the State Bank of Vietnam should play a leading role, proactively coordinating with the Ministry of Finance (Tax Department) to issue general guidance documents, applied synchronously nationwide.
In addition, credit institutions also proposed that VNBA continue to synthesize detailed recommendations to send to the Ministry of Justice, the Ministry of Finance and relevant agencies. At the same time, it is recommended to coordinate with the Ministry of Finance (Tax Department) to organize specialized training courses to directly answer practical situations for credit institutions, enhance dialogue between credit institutions and management agencies so that future regulations are closer to the specific operations of the banking sector.
Taking note of the opinions at the meeting, representatives of the Department of Finance and Accounting and the Department of Credit for Economic Sectors under the State Bank of Vietnam had discussions and feedback on the proposal to guide the principles of unifying fees in credit granting activities and accounting for deposit certificates, in order to find solutions.
Concluding the meeting, Dr. Nguyen Quoc Hung affirmed that VNBA will quickly complete the proposal document, promptly and fully reflecting the enthusiastic opinions of its members. He also expressed his hope that the recommendations of credit institutions will be handled, resolved, and achieve positive results. The ultimate goal is to ensure legal consistency, minimize risks and compliance costs, create conditions for credit institutions to operate safely, transparently and effectively, and contribute to the stability and development of the financial and banking markets.
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