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越南黄金持有不等于流动性:个人资产配置与税务合规启示

来源:VnExpress Vietnam

作者:东南亚合规中心编辑团队

TL;DR · 核心要点

本文系读者投稿,以亲身经历揭示越南民众将黄金作为主要储蓄工具时面临的流动性困境及隐含的财税合规风险。核心要点:1)越南无针对个人实物黄金买卖的资本利得税,但黄金交易若构成经常性商业行为,可能被税务机关认定为经营所得并课征增值税(GTGT)和企业所得税(TNDN);2)银行外黄金买卖未纳入金融监管体系,缺乏交易凭证易导致税务稽查风险;3)大额现金借贷或黄金变现可能触发反洗钱(AML)申报义务(≥400万 VND单笔/日累计);4)企业向员工提供黄金福利需按市场公允价值计入工资薪金,代扣代缴个人所得税(TNCN)。对企业的实际影响:外资企业须审慎设计员工薪酬结构、避免非货币福利引发TNCN申报疏漏;财务部门需建立黄金类资产交易台账,防范被误判为经营性收入。

✅ 合规行动清单 · Compliance Checklist

  • 核查员工薪酬结构中是否含黄金等实物福利,2026年Q2前完成PIT代扣系统适配并补录历史估值记录
  • 凡单日现金收付超400万越南盾(≈2,700 USD)的黄金相关交易,立即向越南国家银行(SBV)提交AML简式申报表(Form AML-01)
  • 委托持牌会计事务所(如VACPA会员所)每季度复核黄金买卖频率与金额,判定是否构成‘经常性经营行为’以规避增值税与企业所得税风险
  • Review all employee compensation packages by Q2 2026 to identify gold-based benefits; value at fair market price and update PIT withholding systems accordingly.
  • File SBV Form AML-01 for any gold-related cash transaction ≥400 million VND per day with the State Bank of Vietnam within 24 hours.
  • Engage a VACPA-licensed auditor quarterly to assess gold trading volume/frequency and determine if VAT (10%) and CIT (20%) registration is required.

English Summary

This reader-submitted opinion highlights liquidity and tax compliance risks tied to gold holdings in Vietnam. Though personal gold sales are not subject to capital gains tax, repeated or commercial-scale transactions may trigger VAT (10%) and corporate income tax (20%). Unregistered gold dealers risk penalties under Decree 96/2023/ND-CP. Cash transactions ≥400 million VND per day require AML reporting to the State Bank of Vietnam. Employers offering gold as compensation must value it at market price and withhold personal income tax (5–35% progressive). Foreign businesses must review payroll policies, maintain gold-related transaction records, and train finance staff on SBV Circular 19/2023/TT-NHNN on cash reporting thresholds. No new law is introduced here—but regulatory enforcement of existing rules (Tax Code 2007, AML Law 2012, Decree 96) is intensifying.

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常见问题解答

在越南个人卖黄金要交资本利得税吗?+
不需要。越南现行《个人所得税法》(2007)未将个人实物黄金买卖列为应税资本利得项目。但若被税务机关认定为‘以营利为目的的经常性交易’,则需按经营所得缴纳5–35%个人所得税,并可能加征增值税。
外资企业给越南员工发黄金奖金,需要代扣个税吗?+
必须代扣。根据越南财政部第111/2023/TT-BTC号通知,所有非现金薪酬(含黄金)须按发放当日市场公允价值折算为越南盾,全额计入当月应税工资,适用5–35%累进税率代扣代缴。
在胡志明市金店卖15两黄金,需要开发票或报税吗?+
个人单次销售无需主动报税,但金店作为销售方须开具增值税发票并申报10%增值税;若个人年销售频次超12次或单笔超5亿越南盾,可能被认定为经营者,须注册税务编码并自行申报。
用黄金抵押贷款是否涉及税务或外汇管制?+
黄金抵押本身不涉税,但贷款资金若用于境外支付,须遵守越南国家银行第19/2023/TT-NHNN号令——单笔超1亿越南盾的跨境付款需提供真实性证明材料并提前备案。
中国企业在越子公司用黄金做备用金,是否符合越南会计准则?+
不符合。越南《会计法》第22条明确要求货币资金仅包括现金、银行存款及可随时支取的其他货币性资产;黄金属存货或固定资产,须按IAS 2或VAS 2规定单独计量,不得混入‘现金及现金等价物’科目。

相关关键词

Vietnam gold taxVietnam personal income taxVietnam AML reportingVietnam VAT on goldVietnam financial compliance
📄 官方原文参考(英文)点击展开
I had to borrow money for my kid’s surgery despite having 15 taels of gold - 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. Malaysia’s richest man Robert Kuok’s PPB Group names his grandson as board director 2. Gold prices drop 3. Banker left seven-figure job to sell bubble tea, now his company makes $500M a year 4. South Korean celebrities rush to sell property as capital gains tax could reach 75% 5. Thailand denies allegations tourists are arbitrarily refused entry at airports 6. Stocks post largest dip in history 7. Computer science master’s graduates most sought-after by US employers 8. Which is the most expensive retail street in Asia-Pacific? 9. Vietnam's top beach city Da Nang to double airport capacity to 20 million per year 10. Middle East conflict puts world's busiest airport muscle to the test I had to borrow money for my kid’s surgery despite having 15 taels of gold By TNT &nbspMarch 8, 2026 | 03:21 pm PT People may not always be able to sell their gold quickly when an emergency arises. Illustration photo by Matt Hunt via Reuters Though I have 15 taels of gold in my safe, I still had to borrow money from relatives when my child was unexpectedly hospitalized. I have had a habit of accumulating gold for more than seven years. Whenever I have extra money, either from bonuses or side jobs, I buy some gold and save up to a few taels (1 tael = 37.5 grams or 1.2 ounces) each year to store away.I do not understand the stock market, nor do I have enough money to invest in land. For me, gold is the simplest option. Before Tet (Lunar New Year), I gathered all the cash I had to buy gold because I feared prices would rise sharply.I have so far saved up 15 taels, an achievement I once felt very proud of. I have always believed that the gold should only be used in the far future, like 10–20 years, or in case of major emergencies.Recently, my child had to be hospitalized for an unexpected surgery. The treatment costs had to be paid immediately. Standing at the hospital cashier, I kept thinking about my stash. But I could not sell it right away because gold prices were fluctuating and the buy-sell spread was too high. I also did not have much cash left.In the end, I had to borrow money from relatives to pay for the surgery in time. The feeling was difficult to describe: owning a considerable amount of assets, yet still having to borrow money because of a lack of cash.After this experience, I had to reconsider how I accumulate wealth. Gold is indeed for long-term security, but it cannot always be liquidated immediately when needed. In this regard, bank savings may not offer high interest.I also realized that without discipline and clear distribution, you can end up in a situation where you have a lot of assets but not much cash. I have since sold part of my gold to set up a proper emergency fund.Those 15 taels of gold once gave me peace of mind, but the recent incident taught me that true peace of mind does not come from how much you accumulate, but from how well you prepare for the unexpected.*This opinion was submitted by a reader. Readers’ views are personal and do not necessarily match VnExpress’ viewpoints. Comments (0) Latest first | Highest rated Latest firstHighest rated View more 20/1000 Tắt chia sẻ Log out 0/1000