The birth of Circular 44/2017 caused a great disturbance for many fields, especially in the field of basic construction, which caused a sharp increase in land and sand for sand leveling as well as stone of all kinds of construction, so that increasing the cost of capital construction works, increasing the burden on the budget, creating conditions for organizations and individuals for illegally exploitation of sand developed. The increasing budget sources by increasing land and sand prices for sand leveling increasing as well as increasing sand and stone prices of construction which was one of the budget sources lost. The company would like to prove as follows:

 Because state management still had many loopholes and problems, the state only managed enterprises which had exploitation licenses, and basic construction works using budget capital and related to capital. In addition, all other projects that did not use budget capital were unable to manage. Therefore, revenues such as natural resource tax on environmental protection fees for mining rights were only collected when the units construction needed invoices, while constructions by people, which almost 100% did not need invoices, so they went to illegally exploitation units that had the cheap prices, even constructions using budget capital also went to these organizations, then legalization of invoices, in these cases, the state were unable to collect any amount. Thus it was a mistake for specialized agencies when they mentioned about raising prices for increasing budget revenues because of two reasons:

    1/. When increasing land and sand levelling prices as well as construction sand and stone prices to increasing budget revenues, immediately costs for these materials source increased tens times or even hundreds times compared to the budget collected. It made construction prices increase and the budget had to pay for costs.

     2/. While businesses with mining licenses are miserable because of increased mining rights grants, increased royalties, increased environmental fees, increased examination and inspection costs, and increased costs of implementing administrative procedures, the organizations and individuals exploiting illegal land, sand and stone who impassibly entice customers to make profit and develop.

   Starting from the reasons mentioned above, the Company proposed that it needed to drafti the Circular to be amended and supplemented as follows:

1. Land Prices and sand leveling prices should only be regulated from VND 15,000 - VND 40,000 / m3 because the average price of land in 7 localities is only VND 26,700 / m3, it means that there were still many other localities with land prices lower than VND 26,700/m3, as in Van Ninh, Khanh Hoa only ranged from VND 20,000 - VND 25,000 / m3 included VAT invoice.
2. Construction sand prices should only be regulated from VND 70,000 - 120,000 / m3 because the average price of 7 localities was only VND 105,000 / m3
3. Price of original stone (stone after blasting) should be regulated from VND 35,000 to 60,000 / m3 because the average price of 7 localities was only VND 49,000 / m3. The price of original stone in Khanh Hoa was only VND 30,000 - VND 50,000/m3 and there were certainly many other localities, which were much lower than the price that the ministry surveyed as above. If it was high, it must still be paid according to the state selling price.  

In the draft, taking the average price through the survey to determining the lowest price, it was accidentally forced the localities with stable prices increased, it made the cost of works also rise, burden on the budget and caused market disorders...

     4 /. In the draft, stone after blasting (minerals after exploitation) was not adjusted, this was the most pressing issue of stone mining enterprises and construction stone producers. The company had proposed many times but it was not resolved yet. The Circular 44/2017 / TT - BTC dated May 12, 2017 regulating the natural resource tax collected on the price of products after processing, leading to taxes stacked up taxes, and fees stacked up fees, in contrary to the natural resource tax law, the Decree No. 50/2010 / ND / CP dated May 14, 2010, the Decree 12/2015 / ND / CP dated 12 February 2015, the Decree 158/2026 / ND / CP dated November 29 / 2016, the Circular 152/2015 / TT and the Circular 44/2017 / TT. Circular 25 / TT / 2018 ... of the Ministry of Finance. This reflects the lack of uniformity in law enforcement, it cased the decree was higher than the law, the circular was higher than the provincial decree and decision higher than the circular, higher than the government decree, the same circular. , the same decree and the same circular but each province performed differently, each person understood differently etc. As we all knew the the stone construction price included many costs associated with it, In which:

  Gasoline costs

  - Electricity production costs

  - Directly and indirectly salaries

  - Replacement materials costs

  - Repair costs

  - Basic depreciation costs

  - Bank interest expenses

  - Expenses for labor protective clothing, poisoning and shifting meals, etc.

  -  Transportation costs

  - Environmental fees, mining rights grant ...

     All were subject to 10% natural resource tax which was unacceptable. Therefore, the companywould like to recommend: Raw stones (stones after blasting) must be adjusted at this modification to suit the actual production situation of enterprises in the whole country to reduce the tax burden. charges for businesses.