Google AdSense Revenue of a Vietnamese Company Subject to 10% VAT, per Phu Tho Tax Office No. 7
A Vietnamese company that designs and runs websites and takes part in Google AdSense places Google ad code on its sites and is paid by Google Asia Pacific Pte. Ltd. (Singapore). It asked whether this revenue is an export service at 0% VAT, what documents are needed, and otherwise which rate applies. Phu Tho Tax Office No. 7 answered that revenue from placing Google ad code on the company's website and earning income under Google AdSense's own policy falls under the 10% rate in clause 3, Article 9 of Law No. 48/2024/QH15. Online advertising is classified under industry 7310 - Advertising. The answer lists no supporting documents and gives no detailed reasoning; the tax office asks the company to compare the legal provisions with its actual circumstances and comply accordingly.
RegHub explainer by New MarketerLast updated:
Based on:Luật số 48/2024/QH15; Nghị định số 181/2025/NĐ-CP - Ministry of FinanceEffective:
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.
Google AdSense Revenue: 0% Export Service or 10% VAT?
The company's situation
- A Vietnamese company designs, programs, develops, technically manages and operates websites it controls.
- It takes part in Google AdSense under terms of Google Asia Pacific Pte. Ltd. (Singapore) and integrates Google's ad code into ad positions on its websites.
- Google decides ad distribution, selects advertisers, sets the display mechanism, measures impressions and collects money from advertisers. The company does not sign contracts with, quote to, invoice or collect money directly from advertisers.
- According to traffic data, the users generating the revenue have IP addresses outside Vietnam; ad space is not shown to users with Vietnam IPs.
- Google pays the company under AdSense's own mechanism.
The company's questions
- Is this revenue a digital service export, and what documents are needed to apply 0% VAT?
- If not, what VAT rate applies and which category does the service fall under?
Answer from Phu Tho Tax Office No. 7
Legal basis cited in the answer
- Article 9 of VAT Law No. 48/2024/QH15 (26/11/2024): the 0% rate applies to exported services, including services provided directly to foreign organizations or individuals and consumed outside Vietnam. The 10% rate applies to goods and services not covered by clauses 1 and 2, including services supplied by foreign providers without a permanent establishment in Vietnam to Vietnamese organizations or individuals via e-commerce and digital platforms.
- Articles 17 and 18 of Decree No. 181/2025/NĐ-CP (01/07/2025): restate the 0% rate for exported services; conditions include a service contract with a foreign organization or individual or one in a non-tariff zone, and non-cash payment documents (except cases in clauses 3, 4, 5 of Article 18).
Conclusion
- Where the company earns revenue from placing Google-provided ad code on ad positions of its website and receives income under Google AdSense's own policy, this revenue falls under the 10% rate under clause 3, Article 9 of Law No. 48/2024/QH15.
- Online advertising falls under group 7310 - Advertising in the Vietnam Economic Sector Classification.
- The tax office asks the company to compare the legal provisions with its actual circumstances and comply accordingly.
Note
The answer does not list supporting documents, does not analyse each condition of the 0% rate separately, and gives no guidance on amending earlier returns. Companies should check their own facts or ask their managing tax office for more detail.