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Q&A on the Circular No 72/2014/TT-BTC dated 30 May 2014 on regulating Value Added Tax (VAT) refund for goods purchased by foreigners and Vietnamese residents overseas departing Vietnam

4/08/2014 12:00 AM


Question 1. Who are the subjects of VAT refund for goods purchased in Vietnam when departing Vietnam?

Answer:

Article 1 of the Circular No 72/2014/TT-BTC dated 30 May 2014 stipulates two (02) subjects of VAT refund, including foreigners, overseas Vietnamese, except for members of flight crew in accordance with the Aviation Law, members of sailor crew in accordance with the Marinetime Law (hereinafter referred to as foreigners) whose passports or entry/exit documents are issued by foreign authorities and valid for entering and exiting Vietnam, purchasing and bringing goods overseas through ports of entry/exit where VAT refund is available.


Question 2. Where are the locations for physical inspection of goods, checking invoice/VAT refund declaration, and locations for paying VAT refunds?

Answer:

According to Article 4 of Circular No 72/2014/TT-BTC dated 30 May 2014, the locations for physical inspection of goods, checking invoice/VAT refund and paying VAT refund amount are regulated as follows:

1. The location for physical inspection of goods, checking invoice/ VAT refund declaration is at the baggage check-in counters and/or boarding-pass checking areas.

At Noi Bai and Tan Son Nhat International Airport: the locations for physical inspection of goods, checking invoice/VAT refund are located at the baggage check-in counters and/or boarding-pass checking areas in order for physical inspection of refunded goods sent by luggage; at the isolated areas in order for physical inspection of refunded portable goods.

2. The location for VAT refund payment is placed within restricted areas of international airports, VAT refund counters at international seaports, which have separate counters (kiosks) and are qualified for cash management and accounting documents in accordance with laws.

 

Question 3.  What are rights and obligations of foreigners purchasing goods in Vietnam and bringing the goods overseas through ports of entry with VAT refund?

Answer:

According to Article 5 of Circular No 72/2014/TT-BTC dated 30 May 2014, rights and obligations of foreigners are stipulated as follows:

- To be refunded with VAT for eligible goods in accordance with Article 11 of Circular No 72/2014/TT-BTC dated 30/5/2014.

- To be guided and provided with necessary information and documents in order to implement tax obligations and rights.

- To appeal and bring in a lawsuit against administrative decisions and actions affecting their legal rights and interests.

- To denounce illegal acts of Customs officers, tax officers and other organizations and individuals concerned.

- To check information in VAT invoice/ VAT refund declaration (hereinafter referred to as invoice/ VAT refund) issued by the selling enterprises in accordance with Index 3 of Circular No 72/2014/TT-BTC dated 30/5/2014.

- To bear all legal responsibilities on the accuracy, legality and authenticity of their passports, entry/exit documents submitted to the selling enterprises; to the Customs Administration and documents submitted to commercial banks as VAT refund agents before departure.

- To submit invoice/ VAT refund declaration and show purchased goods to the Customs administration 30 minutes at the latest before departure


Question 4. What are rights and obligations of the enterprises selling VAT-refund goods?

Answer:

According to Article 6 of Circular No 72/2014/TT-BTC dated 30 May 2014, rights and obligations of the enterprises selling VAT-refund goods are stipulated as follows:

- To make use of advertising on selling  VAT-refund goods for departing foreigners in accordance with the Law on Advertising

- To be guided to refund VAT for foreign passengers by Tax administration and Customs administration.

- To take part in electronic management system of VAT refunds of the Tax administration for foreigners

- To assume other rights in accordance with Law on Tax Administration and other laws concerned.

- To register the right address and bear all legal responsibilities on the registration of selling goods with VAT refunds

- To display a notice board on selling goods with VAT refunds (in English and Vietnamese) and to remove the board after termination.

 - To print, issue, manage and use invoice/ VAT refund declaration, to make report in accordance with the law on invoice of selling goods and providing services in accordance with Circular No 72/2014/TT-BTC dated 30/5/2014.

- To support and instruct foreigners to have VAT amount refunded for goods purchased in Vietnam when being brought abroad in accordance with this Circular No 72/2014/TT-BTC dated 30/5/2014.

- Based on information on valid passports or entry/exit documents and purchased goods, to issue invoice/ VAT refund declaration for goods eligible for VAT refund in accordance with Article 11 of this Circular, to fulfill all information required in accordance with Index 3 of this Circular, then to hand over a copy to foreigners.

- To assume other obligations in accordance with Law on Tax Administration and other laws concerned.


Question 5. Rights and obligations of commercial banks which are selected to be VAT refund agents

Answer:

According to Article 7 of Circular No 72/2014/TT-BTC dated 30 May 2014, rights and obligations of commercial banks as follows:

- To be guided to refund VAT for foreign passengers by Tax administration and Customs administration.

- To display a notice board of the bank acting as the VAT refund agent at VAT refund counters (in English and Vietnamese) and to remove the board if the bank is no longer a VAT refund agent.

- To receive service charges from the VAT refund service for foreigners in accordance with regulation stipulated at Article 12 of Circular Number 72/2014/TT-BTC dated 30/5/2014.

- To take part in electronic management system of VAT refunds of the Tax administration.

- To assume other rights in accordance with the Tax Administration Law and other relevant laws.

- To declare and pay tax for service charges received from supplying VAT refund service for foreigners.

- To check VAT refund record, arrange staff and facilities, pay in advance and refund VAT for foreign passengers, conduct payment procedures with tax offices according to the regulations at Article 21 of this Circular number 72/2014/TT-BTC dated 30/5/2014.

- To sell foreign currencies to foreigners who are refunded VAT when requested to exchange the amount of refunded VAT to foreign currencies, and to make reports in accordance with the law.

- To file records of VAT refund, records of VAT advance payment and service charges in accordance with the law.

- To report offenses detected via checking VAT refund records to competent authorities in accordance with the law.

- To arrange staff working in all day including holidays and Sundays and beyond working hours to perform VAT refund for foreigners as defined in the Circular Number 72/2014/TT-BTC dated 30/5/2014.

- To assume other obligations in accordance with the Tax Administration Law and other relevant laws.


Question 6. What are the responsibilities and rights of customs authority when implementing VAT refund for foreigners?

Answer:

Article 8 of Circular No 72/2014/TT-BTC dated 30 May 2014 stipulates responsibilities and rights of customs authority as below:

- To propagate, disseminate, guide and provide foreigners with information on VAT refund.

- To check passport or immigration papers, invoices cum VAT refund declaration, to conduct physical inspection on goods of foreign passengers presented at checking counters.

- The Manager of a customs branch makes decision on the receipt of invoices cum VAT refund declaration and goods presented after the expiry date prescribed at Clause 5 of Article 5 of Circular Number 72/2014/TT-BTC dated 30/5/2014.

- To receive dossiers and submit to the Ministry of Finance to select banks to be entitled as VAT refund agent in accordance with Article 15 of Circular Number 72/2014/TT-BTC dated 30/5/2014.

- To update information on foreigners and refunded amount of VAT to the VAT refund database for goods purchased by foreigners.

- To coordinate with the counterpart State Treasury and Tax Department in order to check and review the VAT money paid in advance to foreigners by banks and service charges paid to banks to ensure data matching among parties.

- To develop an electronic VAT refund management system compatible with Tax administration’s.

- To settle complaints and denunciations related to VAT refund to foreigners within their assigned competence.

- Penalize, recommend to competent authorities in penalization of offences related to VAT refund for foreigners in accordance with the law.

 - To arrange staff working in all day including holidays and Sundays and beyond working hours to perform VAT refund for foreigners as defined in the Circular Number 72/2014/TT-BTC dated 30/5/2014.

- To perform others duties in accordance with the Tax Management Law and other related laws.


Question 7: What are responsibilities and authorities of Tax Administration in implementing VAT refund to foreign passengers?

Answer:

According to Article 9 of Circular No 72/2014/TT-BTC dated 30 May 2014, Tax Administration has the following responsibilities and authorities:

- Supporting, propagating, disseminating, guiding, explaining and providing with information about VAT refund to foreign passengers.

- Receiving documents, selecting enterprises selling goods as stipulated in this Circular.

- Checking documents, conducting procedures to refund the VAT amount paid in advance by commercial banks to foreign passengers and service charges for VAT refund to commercial banks so that the State Treasury is able to transfer money to the bank in line with this Circular

- Keeping records relating to VAT refund and service charges paid to the commercial bank in accordance with the law.

- Leading in cooperation with the State Treasury, Customs Department at the same level to review and check the amount of VAT that commercial banks paid in advance to foreign passengers (with attached list in detail), the service charges for VAT refund actually paid to the commercial banks to make sure data consistency among the parties.

- Handing violations of regulations on invoices in accordance with the laws.

- Settling complaints and denunciations related to the implementation of VAT refund to foreign passengers within assigned responsibilities.

- Participating to systems of management of VAT refund to foreign passengers in electronic mode of Tax Administration.

- Performing other responsibilities and authorities in accordance with Tax Management Law and other related laws.


Question 8: What kind of goods subjected to VAT refund?

Answer:

According to Article 11 of Circular No 72/2014/TT-BTC dated 30 May 2014, goods subjected to VAT refund shall satisfy the following regulations:

- Goods are not included in the list of goods prohibited from exportation; the list of export goods under permits of the Ministry of Trade (now the Ministry of Industry and Trade) or export list subject to specialized management according to the Decree No 187/2013/NĐ-CP dated 20/11/2013 of the Government and the guidelines thereof.

- Goods are subjected to VAT as stipulated in Article 3 of the VAT Tax Law No 13/2008/QH12 dated 3/6/2008 and the guidelines thereof.

- Goods are not in the list of goods prohibited in airplane as stipulated in Article 12 of the Vietnam Civil Aviation Law dated 29/6/2006 and the guidelines thereof.

- Goods are not subjected to VAT refund of foreigners according to the Circular 08/2003/TT-BTC dated 15/1/2003 of the Ministry of Finance which guides VAT refund for diplomatic missions, consular posts and representative offices of international organizations in Vietnam.

- Goods purchased in Vietnam with invoice cum tax refund declaration which is issued within maximum 60 days before the date of departure of foreign passengers from Vietnam.

- Minimum value of goods in the invoice cum tax refund declaration purchased at the same seller in the same day (including accumulation of many same-day invoices from the same seller) is at least 02 million Vietnamese dong.


Question 9: How to calculate VAT refund amount?

Answer:

According to Item 2, Article 12 of Circular No 72/2014/TT-BTC dated 30 May 2014, VAT refund amount shall be stipulated as below:

Amount of VAT refunded to foreign passengers is 85% (eighty percent) of the total amount of the VAT of the goods which are eligible to be refunded and brought along by foreign passengers when exiting Vietnam via checkpoints where VAT refund is allowed to be implemented.


Question 10. Whether shall foreigners be received VAT refunded amount by Vietnam dong or foreign currency? What is the exchange rate?

Answer:

Article 12 of Circular No 72/2014/TT-BTC dated 30 May 2014 stipulates as below:

- Refunded currency is Vietnamese dong. In case foreign passengers request to exchange Vietnamese dong to a free convertible foreign currency, Commercial Banks will sell the requested foreign currency to foreign passengers in accordance with regulations of the law.

- Exchange rate is quoted by Commercial Banks at the time of exchanging in accordance with regulations of the State Bank of Vietnam.


Question 11.  What is the process of VAT refund which foreigners shall be conducted?

Answer:

The process of VAT refund shall be conducted as the following stages:

1. Stage 1: Foreigners purchasing goods at enterprises selected for selling VAT refund goods (as published on the website of General Department of Tax www.gdt.gov.vn) shall be noticed to check the information in invoice cum tax refund declaration (date of issuing invoice; full name, passport number of buyers…). If the information is not correct and completed, foreigners shall request for correction; but if it is correct and completed, they shall sign in the invoice cum tax refund declaration.

2. Stage 2: Foreigners shall be requested to submit invoice cum tax refund declaration and present refunded goods to customs authority.

+ in Noi Bai and Tan Son Nhat International Airport, foreigners shall submit invoice cum tax refund declaration and present goods to customs authority at invoice cum tax refund declaration checking counters outside of the restricted areas in order for customs officers to check before conducting procedures for sending baggage. After customs authority checks invoice cum tax refund declaration and goods, foreigners shall continue to conduct procedures for sending goods and take their boarding-pass.

In case foreigners request for refund payment to their hand luggage, after coming into the restricted areas, they shall submit invoice cum tax refund declaration and present refunded goods as requested. Customs Authority shall check invoice cum tax refund declaration and goods (if necessary) and calculate the VAT amount refunded to foreigners.

+ in the other places of tax refund, refunded hand goods or baggage shall be subjected to customs inspection outside the restricted areas (in international airports) and in the refund areas (in international seaports).

3. Stage 3: Foreigners shall present their boarding-pass card and invoice cum tax refund declaration checked by Customs Authority in terms of identifying kinds of goods and calculating VAT amount refunded to foreigners, and stamp at tax refund counters in restricted areas.

Commercial Banks shall pay the amount of VAT refunded to foreigners as calculated by Customs Authority. In case foreigners request to exchange the amount of tax refund from Vietnamese dong into free convertible foreign currency, Commercial Banks shall sell the requested foreign currency to foreigners in accordance with regulations of the law. Exchange rate is quoted by Commercial Banks at the time of exchanging in accordance with the regulations of the State Bank of Vietnam.


Question 12. How are procedures for presenting, checking invoice cum tax refund declaration and goods conducted?

Answer:

Procedures for presenting, checking invoice cum tax refund declaration and goods shall be conducted as follows:

1. Foreigners shall present to the customs officials at the invoices cum tax refund declaration and goods checking counter the following documents:

- Passports or exit and entry permits;

- Invoice cum tax refund declaration;

- Goods.

2. Customs officials shall conduct physical inspection of goods at the invoices cum tax refund declaration and goods checking counter. The inspection process is carried out as follows:

- Compare information on passports and exit and entry permits with information on invoices cum VAT refund declaration and regulations prescribed in Article 11 of this Circular on goods to be eligible for VAT refund;

- Conduct physical inspection of goods for those subjected to physical inspection based on the principles of risk management’;

- Record inspection results; identify the goods, calculate the amount of VAT foreigners are refunded as prescribed in Article 12 of this Circular; sign and stamp on invoices cum tax refund declaration;

- Update information of foreigners, amount of actually refunded VAT to the VAT refund database of the customs administration as specified in Appendix 4 of this Circular.


Question 13. How are procedures for VAT refund payment to the foreigners on exit producted?

Answer:

Procedures for VAT refund payment to the foreigners on exit shall be conducted as follows:

1. Foreigners shall:

After the customs inspection on invoices cum VAT refund declaration and goods has been completed, foreign passengers shall present to the commercial banks at refunding counter the following documents:

- Boarding pass;

- Invoices cum VAT refund declaration being checked, calculated the amount of money of VAT and stamped by customs officials (original copy).

2. Commercial banks shall:

- Check the boarding pass; invoices cum VAT refund declaration inspected and stamped by Customs;

- Write the number, date of flight/vessel in the invoices cum VAT refund declaration;

- Refund tax to foreign passengers. This amount is accordance with the one calculated by customs officials in the invoices. Sign and stamp on the invoices to certify;

- Return the boarding pass to foreign passenger;

- File the required documents as regulated.

 

Question 14. What are the criteria used for selection of enterprises selling VAT refund goods?

Answer:

To be selected as a seller, an enterprise has to meet the following conditions:

1. To be established and operated under the provisions of the law of Vietnam, already registered as a VAT refund seller, trading tax-refund goods in accordance with Article 11 of this Circular in one of the following locations:

- The Headquarter of the enterprise;

- The Branches, the stores of the enterprise;

- The location of the sales agents for the enterprise;

2. To comply with regulations on accounting, invoices and vouchers as prescribed in the law; to declare and to pay value added tax under the deduction method.


Question 15. What are types of Registration dossier for selling VAT-refund goods?

Answer:

 Registration dossier for selling VAT-refund goods includes:

- A written registration form to participate in sales as specified in Appendix 1 of Circular No. 72/2014/TT-BTC dated 30 May 2014;

- The certificate of business registration or the certificate of enterprise registration: 01 acknowledge copy of the enterprise;

- The sales agent contract signed between the registered businesses and the sales agent stores for the business (for the case of a store selling agents for enterprises): 01 copy stamped confirmation of the enterprise.


Question 16. How to implement procedures for selection of enterprise selling VAT refund goods?

Answer:

Procedures for selection of enterprise selling VAT refund goods are implemented as follow:

1. Enterprises submit registration dossiers to the tax offices directly managing them;

2. The Tax office directly managing the enterprises receives, inspects the dossiers and proceeds as follows:

- If the dossiers are incomplete, within three (03) working days from the receiving date of the dossiers, the tax office shall have a written notification to the enterprises for supplementary documents;

- If the dossiers do not meet the specified/stipulated conditions, within seven (07) working days from the receiving date of the complete dossiers, the tax office shall have a written document/reply to the Enterprises;

- If the dossiers are complete and meet the requirements of  the regulations,  within seven (07) working days from the receiving date of the dossiers, the tax office directly managing the Enterprises shall report the Tax Department of the province, centrally-run city where the Enterprises are headquartered, such Tax Department shall have written notification to the Enterprises in the specified form in Appendix 2 of Circular No. 72/2014/TT-BTC dated 30 May 2014.


Question 17. What are the procedures to adjust and terminate sale of VAT refund goods?

Answer:

Procedures to adjust and terminate sale of VAT refund goods are as follows:

If an enterprise which is informed by local Tax Department, where its headquarter is located, to be qualified to sell VAT refund goods, wants to make any adjustment or termination of the selling, they should conduct the following procedures should be followed:

1. In case of adjustment:

a) The enterprise shall send the Tax Departments adjustment documents in accordance with the form regulated in Appendix 8 of Circular No. 72/2014/TT-BTC dated 30 May 2014; agent contracts between the enterprise selling VAT refund goods and its agent stores (in case the stores are agents for the enterprise): 01 acknowledged copy;

b) The procedure is the same as the procedure regulated in Paragraph 3 of Circular No. 72/2014/TT-BTC dated 30 May 2014.

2. In case of termination:

a) At least 30 (thirty) days before the termination of the selling of tax refund goods, the enterprise has to submit a written notification to tax office directly managing her;

b) Within thirty (30) days from the receiving date of enterprise’s documents, such tax office shall examine and report to the Provincial/ centrally-run city Tax Department, where the business is headquartered, in order that the Provincial/ centrally-run city Tax Department shall send a written notification to enterprise, customs administration, commercial bank on the termination.

Enterprise shall remove the notification board as VAT refund sales agents for foreigners shown at the store when terminating.

3. Where enterprises violate the regulations on the VAT refund specified in Circular No 72/2014/TT-BTC dated 30/5/2014, the Provincial/ centrally-run city Tax Department shall consider and decide on the termination of the tax refund sales:

a) The Provincial/ centrally-run city Tax Department shall send the written notification on the termination of tax refund sales to the enterprise, and simultaneously send it to the customs administration, commercial bank and related entities;

b) The enterprise shall remove the notification board as the VAT refund sales agent shown at its stores upon the termination of tax refund sales.


Question 18. How are the print, issuance, management and use of invoice cum value-added-tax refund declaration stipulated?

Answer:

The print, issuance, management and use cum value-added-tax refund declaration are stipulated as follows:

1. Enterprises print invoice cum VAT refund declaration by themselves as prescribed in Appendix 3 of Circular No 72/2014/TT-BTC dated 30/5/2014.

The printing, issuing, managing and using of invoice cum tax refund declaration shall comply with the provisions of Decree No 51/2010/NĐ-CP dated 14/5/2010 of the Government on sales and services supply invoices; Decree No 04/2014/NĐ-CP dated 17/1/2014 of the Government amending and supplementing a number of Articles of Decree No 51/2010/NĐ-CP and Circular No 39/2014/TT-BTC dated 31/3/2014 of Minister of Finance on guidelines of the implementation of Decree No 51/2010/NĐ-CP dated 14/5/2010 of the Government and Decree 04/2014/NĐ-CP dated 17/1/2014 of the Government on sales and services supply invoices.

2. Foreigners shall present valid passports or legal entry/exit documents (original) issued by foreign authorities to the tax refund sales agent when shopping. Based on information in valid passport or entry/exit documents and goods that foreigners actually bought, the agent shall issue invoice cum VAT refund declaration as prescribed in Appendix 3 of Circular No 72/2014/TT-BTC dated 30/5/2014.

3. Foreigners shall check the declared information and request revision in case of incorrect information, or sign in the tax refund invoices in case of correct information.

4. The tax refund sales agent, when declaring monthly VAT declaration profiles, in the “Note column” of Bill Statements, goods and service sales documents form 01-1/GTGT enclosed with Circular No 156/2013/TT-BTC dated 6/11/2013 of the Minister of Finance on guidelines of the implementation of a number of articles of the Law on tax management; the Law amending and supplementing a number of articles of the Law on tax management and Decree No 83/2013/NĐ-CP dated 22/7/2013 of the Government, shall write the respective phrase “Circular No 72/2014/TT-BTC” at the invoice line as the basis to make reports as prescribed in Circular No 72/2014/TT-BTC dated 30/5/2014.

5. Updating information on the invoices cum VAT refund declaration established by the tax refund sales agent to the VAT refund management system for foreigners.


Question 19. What are conditions and procedures to be commercial banks as value-added tax refund agents?

Answer:

1. Conditions:

Being commercial banks operating on foreign exchange and providing foreign exchange services in accordance with the law on foreign exchange.

2. Procedures:

2.1. Commercial banks shall submit to the Ministry of Finance (the General Department of Customs) the following documents:

- A written registration on participating as VAT refund agents for foreigners;

- The document issued by the State Bank to permit the commercial banks to operate on foreign exchange and to provide foreign exchange services:  01 acknowledged copy of the commercial banks.

2.2. The General Department of Customs shall receive and examine the dossiers submitted by the commercial banks.

- If the dossiers are uncompleted, within three (03) working days from the date of receiving the dossiers, the General Department of Customs shall send a written notification to the enterprises for supplementary documents;

- If the dossiers do not meet the specified conditions, within seven (07) working days from the date of receiving the dossiers, the General Department of Customs shall send a written response to the banks;

- If the dossiers are completed and meet the specified requirements,  within ten (10) working days from the date of receiving the complete dossiers, the Ministry of Finance (the General Department of Customs) in coordination with the State Bank shall send a written notification to the commercial banks on meeting the conditions to be VAT refund agents.

2.3. On the basis of the proposal and commitment of commercial banks, the General Department of Customs shall agree with the State Bank, the State Treasury, the General Department of Taxation to report to the Ministry of Finance to decide on selecting the commercial bank in line with the actual situations of each international airport and seaport.


Question 20. How are the procedures for the termination of VAT refund agents of commercial banks conducted?

Answer:

Procedures for the termination of VAT refund agents of commercial banks shall be conducted as follows:

1. In case a commercial bank which has been certified in a written notification by the Ministry of Finance to act as a tax refund agent requires terminating its status, the procedure shall be as follows:

1.1. Dossier: At least sixty (60) days before the date of termination to be a tax refund agent, the commercial bank shall submit to the Ministry of Finance (the General Department of Customs) a written document on requesting the termination of being a tax refund agent;

1.2. Procedures:

- Within ten (10) working days from the date of receiving the written document of the commercial bank, the General Department of Customs shall submit to the Ministry of Finance to issue a written notification on the termination of being a tax refund agent to the commercial bank, and simultaneously to the tax administration, the State Bank and other relevant offices;

- The commercial bank shall remove the notification board as a VAT refund agent for foreigners at reimbursement counters upon termination of tax refund agent.

2. Where commercial banks violate the regulations on VAT refund specified in this Circular, the General Department of Customs shall report to the Ministry of Finance for consideration and decision on terminating the grant of the banks as tax refund agents.

2.1. Ministry of Finance (the General Department of Customs) shall send a written request to commercial banks on their termination of being a tax refund agent, and simultaneously to the tax administration, the State Bank and other related entities;

2.2. The commercial bank shall remove the notification board as a VAT refund agent for foreigners at reimbursement counters upon their termination of tax refund agent.


Question 21. How are violations described in Circular No. 72/2014/TT-BTC dated 30th May 2014 handled?

Answer:

Foreigners, Vietnamese residents overseas, tax agencies, customs agencies, tax officials, customs officials, enterprises selling goods with VAT refunded, commercial banks or other relevant organizations, individuals who violate the provisions of this Circular shall be penalized under the provisions of Decree No 127/2013/NĐ-CP dated 15/10/2013 of the Government on penalties for administrative violations and enforcement of administrative decisions pertaining to customs controls, Decree 129/2013/NĐ dated 16/10/2013 of the Government on penalties for administrative violations pertaining taxation and enforcement of administrative decisions on taxation and enforcement of administrative decisions on taxation and legal documents on guiding the implementation of this Decree./.

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