Determining Accrued Savings Deposit Interest When Preparing Financial Statements for a Dissolving Company Under Circular 99/2025/TT-BTC
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Based on:99/2025/TT-BTC - Ministry of Finance
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A company going through dissolution asked the Ministry of Finance (MOF) how far forward it should accrue savings deposit interest when preparing financial statements, given that Circular 99/2025/TT-BTC requires a financial statement once a business is no longer a going concern. MOF's Department of Accounting and Auditing Supervision Management clarified that financial statements must be prepared at the legal 'point of dissolution' under the Law on Enterprises, not at the date the company simply issues its dissolution decision - a distinction many businesses get wrong. For the accrued interest itself, the company should apply the accounting principles for Account 128 (Held-to-Maturity Investments) under Circular 99/2025/TT-BTC together with the specific terms of its deposit contract, recognizing interest consistent with the correctly determined dissolution point rather than any of the three dates it had proposed.
The Question
A company undergoing dissolution asked the Ministry of Finance (MOF) how to determine 'accrued savings deposit interest' when preparing financial statements (FS) at the point its dissolution decision is issued, under Circular No. 99/2025/TT-BTC.
Scenario:
- March 31, 2026: the company issues its dissolution decision.
- The company holds a 6-month term savings deposit contract maturing July 31, 2026.
- Management plans to roll the deposit over for 2 more months once it matures, with an expected new maturity of September 30, 2026.
- The company expects to complete all dissolution procedures (asset liquidation, tax settlement, obligations to related parties, termination of legal status) by March 31, 2027.
The company asked MOF to choose among three options for the accrued-interest cutoff: March 31, 2026; July 31, 2026; or September 30, 2026.
Response from the Department of Accounting and Auditing Supervision Management
1. On the timing of financial statements
Under Point b, Clause 3, Article 15 of Circular No. 99/2025/TT-BTC dated October 27, 2025, an enterprise being divided, consolidated, merged, converted, dissolved, or declared bankrupt must prepare financial statements at the point of division, consolidation, merger, conversion, dissolution, or bankruptcy as prescribed by law.
Clause 1, Article 24 of Circular No. 99/2025/TT-BTC requires an enterprise to assess indicators that it no longer meets the going-concern assumption; an enterprise is considered not a going concern if it is expected to be dissolved, go bankrupt, cease operations, or significantly scale down within 12 months or less from the end of the accounting period.
The Department clarified that accounting law requires financial statements to be prepared at the point of dissolution (not the point the dissolution decision is issued). The point of dissolution itself is determined under the Law on Enterprises, not Circular 99/2025/TT-BTC. The company should therefore rely on the Law on Enterprises to determine its actual dissolution point, and prepare its financial statements at that point following the principles of the current enterprise accounting regime.
2. On accounting for the savings deposit interest
For accrued interest on a short-term savings deposit contract (term under 12 months), the company should apply the terms of its deposit contract together with the guidance in Section 3.1.1, Account 128 - Held-to-Maturity Investments, Part B, Appendix II issued with Circular No. 99/2025/TT-BTC.
In short, MOF did not directly pick one of the company's three proposed options. Instead, it directed the company to first correctly determine the legal dissolution point under the Law on Enterprises, and then apply the Account 128 accounting principles to recognize accrued interest consistent with that point.
Why It Matters
Businesses that are in or approaching dissolution should clearly distinguish between the point a dissolution decision is issued and the legal point of dissolution under the Law on Enterprises, since the latter - not the decision date - is the mandatory cutoff for preparing financial statements under Circular 99/2025/TT-BTC.