Tax for Logistics and International Transport: 5 Points Businesses Get Wrong
Logistics and international transport have a more complex "tax map" than many sectors: one company may issue 0% VAT invoices (international transport), standard-rate invoices (domestic services), and withhold contractor tax when paying foreign shipping lines. An error at any link leads to arrears. This article systematizes the 5 key points.
Contents
- 1. The tax picture of a logistics enterprise
- 2. 0% VAT for international transport — and the documentation trap
- 3. CIT: sector-specific revenue and costs
- 4. Contractor tax on payments to foreign carriers
- 5. DTAs and the international transport article
- 6. Three common audit risks
- 7. Frequently asked questions
- 8. When to work with a lawyer
- References
1. The tax picture of a logistics enterprise
A typical logistics enterprise touches almost every tax:
- VAT: 0% for qualifying international transport; standard rates for domestic services (warehousing, forwarding, domestic transport);
- CIT: on logistics income under the Law on CIT 67/2025;
- Contractor tax: on payments to foreign shipping lines and carriers;
- PIT: for drivers, warehouse and office staff;
- Import/export duties / customs fees: if acting as customs broker (related, though not the enterprise's own tax).
The first requirement of tax accounting here is revenue separation: domestic vs international, as the two streams face entirely different VAT regimes.
2. 0% VAT for international transport — and the documentation trap
International transport qualifies for 0% VAT — a major benefit with strict conditions. In principle, the enterprise needs:
- An international transport contract (or equivalent document);
- Bank payment proof;
- Documents proving the service was performed outside Vietnam (bills of lading, handover records, etc.).
The trap: many enterprises issue 0% invoices without keeping the full dossier. When a tax audit demands proof that cannot be produced, all 0% revenue is reassessed at standard rates plus penalties and late-payment interest. The golden rule: no documents, no 0%.
3. CIT: sector-specific revenue and costs
Taxable CIT revenue for logistics includes freight charges, warehousing, forwarding and agency fees. Deductible costs have frequently disallowed specifics:
- Fuel: the largest cost; valid invoices and reasonable consumption norms required;
- Vehicle repair and maintenance: invoices and acceptance records;
- Depreciation: high-value vehicles — wrong depreciation frames affect many years;
- Off-book costs: informal port payments and uninvoiced expenses — non-deductible and carrying other legal risks.
4. Contractor tax on payments to foreign carriers
When a Vietnamese enterprise (cargo owner or forwarder) pays freight to foreign shipping lines/carriers, the payment may fall under foreign contractor tax. The Vietnamese enterprise must then:
- Withhold tax before paying the foreign party;
- Declare and pay on the foreign contractor's behalf;
- Keep contracts and payment proof.
Missing this is a common error: many assume "paying abroad means no Vietnamese tax" — while the law says the opposite. Assess each contract specifically, together with the relevant DTA.
5. DTAs and the international transport article
Most DTAs signed by Vietnam contain a dedicated international transport article (usually Article 8 under the OECD model): profits from operating ships and aircraft in international transport are taxable only in the enterprise's residence state.
This has major practical significance: a foreign carrier with a DTA with Vietnam may be exempted/reduced from Vietnamese tax on international transport profits — but must complete notification procedures and prove tax residence. No procedure, no benefit.
6. Three common audit risks
- Wrongly applied 0% VAT for missing documents — reassessed at standard rates plus penalties and interest.
- Failure to withhold contractor tax on foreign carrier payments.
- Fuel, repair and depreciation costs lacking invoices — disallowed from deductible CIT expenses.
7. Frequently asked questions
Q: What VAT rate applies to international transport services?
A: International transport qualifies for 0% VAT if contract, documentation and payment conditions are met. Failing the conditions means the standard rate applies, with possible arrears.
Q: What are the conditions for 0% VAT on international transport?
A: In principle: an international transport contract (or equivalent), bank payment proof, and documents proving the service was performed outside Vietnam. Full documentation must be kept for tax audits.
Q: Is foreign contractor tax due when hiring foreign shipping lines?
A: Possibly. When a Vietnamese enterprise pays freight to foreign carriers, the payment may fall under foreign contractor tax — the Vietnamese party must withhold, declare and pay on their behalf.
Q: Do DTAs have special provisions for transport?
A: Yes. Most DTAs signed by Vietnam contain an international transport article (usually Article 8 under the OECD model): profits from international transport are taxable only in the enterprise's residence state. This matters when foreign carriers operate in Vietnam.
Q: What do tax audits of logistics firms usually target?
A: Three common groups: (1) wrongly applied 0% VAT for missing documents; (2) failure to withhold contractor tax on foreign carrier payments; (3) fuel, repair and vehicle depreciation costs lacking invoices.
Q: How are domestic logistics services (warehousing, domestic forwarding) taxed?
A: Logistics services performed within Vietnam are subject to standard VAT rates (no 0% as for international transport). Domestic and international revenue must be separated in filings.
8. When to work with a lawyer
Work with a lawyer when: facing arrears from wrongly applied 0% rates; assessing contractor tax duties in foreign carrier contracts; applying DTAs for foreign partner relief; or reviewing documentation systems before a tax audit. FLAT Law Firm advises logistics and transport enterprises on tax — contact hotline 0988424851.
References
- Law on Value Added Tax and current guiding documents.
- Law on Corporate Income Tax 67/2025/QH15 (effective 01/10/2025).
- Foreign contractor tax regulations and current guiding documents.
- Double taxation agreements signed by Vietnam.
- Content cross-checked at time of writing (28/9/2026).
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