MOF clarifies which column reports revenue below the VAT threshold on Form 01/TKN-CNKD
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Based on:48/2024/QH15 - Ministry of Finance
This explanation was generated by AI and checked by an automated AI review, not by a human expert. It is not legal, tax or accounting advice and may contain errors. Check the official document before you rely on it.
The Ministry of Finance (via Tax Sub-Department 2 of Khanh Hoa Province) answered a household business's question about how to report revenue under 1 billion VND on Form No. 01/TKN-CNKD (issued under Circular 50/2026/TT-BTC), for taxpayers using the declaration method. Asked which column to use for revenue below the taxable threshold, the tax authority did not give a specific answer because the taxpayer did not state its business line, and instructed the reader to contact its managing tax office directly for guidance matching its actual business. On the second question - what cases Column 3, "Revenue not subject to VAT," covers - the Ministry confirmed the line item follows Article 5 of VAT Law No. 48/2024/QH15 (as amended by Law No. 149/2025/QH15 and Law No. 09/2026/QH16): it applies only to unprocessed or only preliminarily processed agricultural, forestry, and aquaculture products sold directly by the producing or catching organization or individual, or such goods at the import stage - not to every household business whose revenue simply falls below the VAT taxable threshold. This is an important clarification for household and individual businesses: revenue below the VAT taxable threshold (currently 1 billion VND) is not automatically the same as "revenue not subject to VAT" under Column 3 - these are two distinct concepts. Businesses should contact their managing tax office directly for guidance on which line item to use based on their specific business line, to avoid a misdeclaration that creates risk later.
Question
A household business (ho kinh doanh) that began operating in early 2026 pays tax under the declaration method. When filing its return for the first half of 2026 using Form No. 01/TKN-CNKD (issued together with Circular No. 50/2026/TT-BTC dated 13 May 2026 of the Minister of Finance), the business - whose total revenue is under 1 billion VND - ran into confusion: some online guides say the entire revenue amount should be entered in Column 3, "Revenue not subject to VAT," while the taxpayer's own reading is that this line item applies only to goods or business lines falling under VAT-exempt categories per the VAT Law. The taxpayer asked the Ministry of Finance to clarify:
- For a household business under the declaration method with revenue below 1 billion VND (below the taxable threshold), which column/line item on Form 01/TKN-CNKD should report that revenue?
- Specifically, what cases does Column 3, "Revenue not subject to VAT," apply to?
Answer
On question 1: Because the reader's (Mr./Ms. Vuong Hong Phuc) question did not specify the business line the household business operates in, the tax authority could not provide precise guidance on which column/line item to use on Form 01/TKN-CNKD. The reader is advised to contact the managing tax authority directly for guidance specific to the actual business line.
On question 2: Pursuant to Article 5 of VAT Law No. 48/2024/QH15 dated 26 November 2024 of the National Assembly, as amended by Point a, Clause 1, Article 1 of the Law amending the VAT Law No. 149/2025/QH15 and Law No. 09/2026/QH16, Article 5 defines "Subjects not subject to tax." Clause 1 states:
Cultivation, planted-forest, livestock, and farmed or caught aquaculture products that have not been processed into other products, or that have only been given ordinary preliminary processing, when sold by the producing or catching organization or individual itself, and at the import stage, are not subject to VAT.
Where an enterprise, cooperative, or union of cooperatives purchases such cultivation, planted-forest, livestock, or aquaculture products (unprocessed or only preliminarily processed) to resell to another enterprise, cooperative, or union of cooperatives, that resale does not need to be declared or have VAT calculated on it, but the related input VAT may still be credited.
Note on scan quality: the reply in the source image is cut off after this quoted excerpt of Article 5, Clause 1 (marked "..."), so any remaining clauses of Article 5 cited in the original official letter are not fully legible from this scan.
Tax Sub-Department 2 of Khanh Hoa Province issued this reply so that Mr./Ms. Vuong Hong Phuc may be informed and comply with the regulations cited above and the guidance in this document.