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June 25, 2025, marked a significant legal milestone in Vietnam as the National Assembly officially passed a law amending eight existing laws. These changes directly impact On-Spot Import/Export activities. As a professional logistics consulting firm, Real Logistics is pleased to provide a comprehensive analysis of these new regulations to help your business seize opportunities and ensure effective compliance.

1. Legal Context & New Policy Content

1.1. Effective Date According to Hai Quan (Customs) Online, the amended law will officially take effect on July 1, 2025. This is a critical deadline for businesses to prepare and adapt their operations.

1.2. Establishing a Transparent Customs Framework

Previously: On-spot import/export operated in a legal "grey area" with unclear customs procedures, leading to difficulties and risks for businesses.
Now (From July 1, 2025): The new regulations completely eliminate this ambiguity. On-spot import/export activities are formalized, requiring businesses to file both export and import customs declarations. All transactions must undergo full customs clearance and are subject to customs supervision, just like goods crossing the border.

1.3. The Core Incentive Remains: 0% VAT Rate Despite stricter procedures, the most important incentive is preserved. Goods traded under on-spot import/export arrangements will continue to enjoy a 0% Value-Added Tax (VAT) rate. This strategic decision is designed to prevent double taxation, protect state budget revenue, and maintain Vietnam's attractive investment climate.

2. The Government's Rationale

The new policy is built on a solid and well-calculated foundation:

Clear Legal Basis: The law aligns with the spirit of Resolution 27-NQ/TW and conclusions from the Politburo, reflecting consistency in Vietnam's economic development strategy.
Ensuring Systemic Consistency: The decision to place the 0% VAT rule within the Law on VAT (rather than the Law on Customs, as initially drafted) ensures uniformity, stability, and synchronization across the legal tax framework.
Protecting Businesses and the Investment Environment: The Ministry of Finance explained that without the continued application of the 0% rate, businesses would face the risk of double taxation, leading to higher costs, reduced competitiveness, and a negative impact on attracting investment.

3. Practical Impacts on Businesses and Supply Chains

Aspect	Benefits & Impact
Costs & Taxes	The 0% VAT rate reduces financial pressure and optimizes cash flow, as businesses no longer need to advance tax payments and wait for refunds. It effectively eliminates double taxation.
Transparent Procedures	Mandatory customs declarations help businesses minimize legal risks and avoid future disputes or penalties. The playing field is now clearer and more equitable for all.
Optimized Supply Chains	Businesses can flexibly buy and sell goods within Vietnam while still receiving export-like incentives. This optimizes raw material sourcing, shortens delivery times, and saves on international transportation costs.
Attracting FDI & High-Tech	A clear legal framework and stable tax policy are powerful incentives for foreign investors, especially in supporting industries, semiconductors, and high-tech sectors, to confidently expand their operations in Vietnam.

4. Key Implementation Notes

Scope of Application: On-spot import/export includes various activities such as goods for processing, raw materials for producing exported goods, and machinery/equipment for creating fixed assets, as defined in Article 86 of Circular 38/2015/TT-BTC (as amended).
Documentation for 0% VAT: Businesses must prepare a complete set of documents, including contracts, invoices, payment receipts, and, crucially, the cleared customs declarations. More detailed guidance is expected to be issued.
Legal Transition: The VAT provisions were moved from the draft Article 47a of the Customs Law and integrated entirely into the Law on VAT. This move creates better synergy and consistency between tax and customs laws.

5. Actionable Recommendations from Real Logistics

To prepare for and maximize the benefits of this new law, at Real Logistics, we strongly recommend businesses take the following steps immediately:

Review and Update Internal Processes: Standardize all procedures, from contract signing and customs declaration to managing records and preparing documents to correctly apply the 0% VAT rate.
Upgrade ERP Systems and Personnel: Consider integrating automated declaration solutions and train relevant staff to handle the new professional requirements efficiently and transparently.
Strengthen Legal Risk Control: Clearly define responsibilities across departments (procurement, import/export, accounting) and establish effective communication channels with customs authorities.
Restructure Supply Chains: Leverage the new policy to prioritize sourcing from domestic suppliers who can provide goods under the on-spot model, thereby saving on international logistics costs.
Prepare to Attract FDI: Proactively promote this favorable on-spot import/export policy to foreign partners and investors as a key competitive advantage of operating in Vietnam.

6. Conclusion

The new regulation on on-spot import/export is a strategic legal step forward. It not only clarifies customs procedures but also solidifies key tax incentives, creating a more transparent and efficient business environment.

For Real Logistics, this presents an opportunity to further enhance our consulting services, partnering with businesses to optimize costs, mitigate legal risks, and welcome the coming wave of high-tech investment into Vietnam.

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Real Logistics Co.,Ltd

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Vietnam's New Law on On-Spot Import/Export (Effective July 1, 2025): A Business Compliance Guide