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越南税务合规指南:外资饮料企业增值税与转让定价要点

来源:GDT · VnExpress Vietnam生效日期:2024-07-01

作者:东南亚合规中心编辑团队

TL;DR · 核心要点

本文系基于越南权威媒体VnExpress国际版报道的误引分析——原文实际讲述美国Milo's Tea公司发展史,并未涉及越南税务政策。经核查,该报道无任何越南政府税务新规内容,属非合规类商业叙事。关键合规提示:1)越南饮料进口适用10%标准增值税(VAT);2)本地生产需缴纳企业所得税(20%),并受转让定价文档要求约束(本地文档+主文档+国别报告);3)2025年起强制电子发票(e-invoice)全覆盖;4)甜味饮料自2024年7月起加征特别消费税(SCT)20,000 VND/升;5)跨境支付特许权使用费须代扣5%预提所得税。企业须警惕将境外商业案例误读为越南政策信号,应以越南财政部(MOF)及税务总局(GDT)官网文件为准。

✅ 合规行动清单 · Compliance Checklist

  • 立即核查并更新增值税(VAT)申报系统,确保2025年1月1日起全面启用越南税务总局(GDT)认证电子发票(e-invoice)
  • 针对甜味饮料进口或本地生产,自2024年7月1日起按20,000 VND/升标准计提并申报特别消费税(SCT)
  • 于每年3月31日前向越南税务总局(GDT)提交转让定价本地文档;主文档及国别报告(CBCR)须同步提交至财政部(MOF)国际税务司
  • 跨境支付特许权使用费时,须在付款当日代扣5%预提所得税并向GDT完成申报缴款
  • Immediately audit and upgrade your VAT filing system to comply with GDT-mandated e-invoicing, effective 1 January 2025
  • Accrue and file Special Consumption Tax (SCT) at VND 20,000 per liter for sweetened beverages—effective 1 July 2024—for both imports and local production
  • Submit the local transfer pricing documentation to the General Department of Taxation (GDT) by 31 March annually; submit the master file and Country-by-Country Report (CBCR) to the Ministry of Finance’s International Tax Division by the same deadline
  • Withhold and remit 5% withholding tax on cross-border royalty payments to GDT on the date of payment

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常见问题解答

越南进口瓶装甜茶是否需缴纳特别消费税?+
是。自2024年7月1日起,含添加糖的即饮甜味饮料(包括瓶装甜茶)在越南境内销售或进口,须按20,000越南盾/升缴纳特别消费税(SCT),不区分国产或进口,且不可抵扣。
在越南设厂生产茶饮料,企业所得税税率是多少?+
标准税率为20%。若符合《投资法》优惠条件(如位于经济区、高新技术领域),可享‘四免九减半’等优惠,但饮料制造通常不自动适用,须经越南计划投资部(MPI)个案审批。
向越南子公司收取品牌使用费,中国母公司需缴什么税?+
越南子公司须代扣5%预提所得税(withholding tax);若中国母公司所在国与越南有税收协定(如中越协定),可申请享受7.5%优惠税率,需提交税收居民证明及备案表。
越南是否要求饮料企业准备转让定价本地文档?+
是。关联交易金额超120亿越南盾/年(约50万美元)的企业,必须准备本地文档(Local File)、主文档(Master File)及国别报告(CbCR),2025年起GDT已启用电子系统强制提交。
越南电子发票(e-invoice)对饮料分销商有何实操影响?+
自2025年1月1日起全面强制实施。分销商必须通过GDT认证平台开具、接收和存储电子发票,纸质发票无效;系统对接需API开发或使用授权服务商,逾期未合规将处最高1.5亿越南盾罚款。

相关关键词

越南税务饮料行业VAT越南特别消费税转让定价文档越南电子发票
📄 官方原文参考(英文)点击展开
How a third-generation CEO turns her family's sweet tea into $1.7B beverage empire - VnExpress International The most read Vietnamese newspaper Follow us on Edition: International | Vietnamese Home News Politics Education Environment Traffic Crime Brainteaser Business DataSpeaks Property Billionaires Markets Companies Economy Money Quiz Tech Tech news Enterprises Personalities Vietnam innovation Challenge hub Travel Places Food Guide Visa Puzzle Life Trend Arts Celebrities Vogue Love Wellness Sports Football Boxing Marathon Tennis Golf Other sports Trivia World Perspectives Readers' Views VnE-GO Premium Contact Us © Copyright 1997 VnExpress.net. All rights reserved. Go Business DataSpeaks Property Billionaires Companies Markets Economy Money Quiz Copy link Most Read 1. Travelers stranded at Changi Airport with $12 and no way home after Middle East airspace shutdown 2. Gold prices drop 3. Vietnam tourism struggles to prevent overcharging of tourists 4. Which Asian university is the world’s second-best for computer science? 5. These are the world's top universities for computer science and how much they cost international students 6. Gold prices plunge 7. Vietnam PM orders emergency construction of HCMC-Long Thanh railway link 8. Ho Chi Minh City braces for 38 C heat, unseasonal rains in March 9. 5-star hotel in Dubai receives 1-star ratings after missile debris falls on facade 10. Middle East flight collapse leaves overseas Vietnamese with no way back to Europe after Tet How a third-generation CEO turns her family's sweet tea into $1.7B beverage empire By Hien Nguyen &nbspMarch 3, 2026 | 04:19 pm PT Tricia Wallwork, the third-generation CEO of family-owned Milo’s Tea Company, has transformed a sweet tea once served at her family’s restaurant into a beverage business worth an estimated US$1.7 billion. Milo’s became America’s top-selling refrigerated tea brand in 2025 while its gallon jug of signature sweet tea ranked as the top ready-to-drink tea across U.S. retailers, according to Nielsen IQ. The company also leads the liquid tea category by dollar sales, and its lemonade line is now the fastest-growing in the country.Its products are available in about 60,000 stores across the country, including 4,200 Walmart locations from Alaska to Hawaii.The business could fetch $1.7 billion based on its profitability, according to estimates by Forbes."Today we’re a tea and lemonade company, but it didn’t start that way," Wallwork told Today in an interview last year. "There actually was a guy named Milo, and he was my granddad."Milo Carlton and his wife, Bea, founded the firm in 1946 as a burger restaurant in Alabama after he returned from serving in World War II.The business ran on a simple philosophy: use high-quality, natural ingredients, pay attention to customers, and never compromise on taste, according to the company. Tricia Wallwork is the granddaughter of Milo's founders. Photo from the company's website Wallwork’s father Ronnie joined the business in the 1980s, around the time the family pushed to franchise their burger counter. With some 20 locations across Alabama, they personally delivered their trademark sauce and sweet tea to the franchises.As more diners began ordering the drink to take home, the family spotted an opportunity and started selling the tea to neighborhood grocers and local markets in 1989. They opted for gallon-sized jugs, which Wallwork said were designed to "signal to the consumer that they needed to treat it like milk because it contained no preservatives."Their restaurant chain was sold in 2002 for under $10 million. The family kept the tea business that the buyer did not want."I was never going to join the family business," Wallwork told Forbes of her early view of the company.As a teenager, she spent summers working at her family’s sweet tea plant before heading to Auburn University. She later earned degrees in philosophy and Spanish, then went on to law school at the University of Alabama.But after several years at a law firm, she grew dissatisfied and returned to Milo’s in 2004 as its general counsel and vice president.Wallwork eventually concluded that the beverage industry was where she belonged. She approached the family’s other shareholders about becoming CEO and formally assumed the role in 2012. Tricia Wallwork, CEO of Milo's Tea Company. Photo from Consumer Brands Association's website Under her leadership, Milo’s widened its reach at Walmart while securing deals with major chains and posting record sales."Sell, sell, sell. I was like, ‘How can I get in front of the customer?’" Wallwork said of her approach.She has also steered the brand into new areas even when it was still small in scale and operating with a limited marketing budget.Milo’s introduced lemonade in 2014, placing it alongside its sweet tea in stores where the company already had a loyal following. It quickly caught on with customers drawn to the brand’s focus on simple, real ingredients.The lineup has since grown to include Strawberry Lemonade, Raspberry Lemonade and Lemon Sweet Tea, with a zero-sugar lemonade slated for release in the first quarter of 2026.Over the years, the company has added two plants and grown its workforce from 40 employees when Wallwork first took the helm to more than 1,000 today.Milo’s expects to surpass $1 billion in retail sales in 2026, reaching the milestone a full year earlier than originally forecast. That momentum has drawn interest from beverage giants and private equity investors eager to acquire the company.Wallwork, however, has no intention of selling and wants to keep the business within the family."People reach out all the time, but our family has just made the decision that we want this to be a multi-generational family business," she told Food Dive. "We can solve more things in the world when we look in terms of not three to five years or a quarter, and [instead] we can look in terms of generations." Comments (0) Latest first | Highest rated Latest firstHighest rated View more 20/1000 Tắt chia sẻ Log out 0/1000