On February 24, 2017, the Government issued a Decree No. 20/2017 / ND-CP regulating tax administration for enterprises with associated transactions (hereinafter referred to as the Decree 20)  that be effective from May 1, 2017. On April 28, 2017, the Ministry of Finance issued a Circular No. 41/2017 / TT-BTC guiding the implementation of a number of articles of the Decree No. 20/2017 / ND-CP.

The process of applying the Decree 20 revealed some problems and difficulties for enterprises operating in real estate business. Especially, item 3 of Article 8 of the Decree 20 / CP. This decree still had some contents that were not consistent with the promulgated Laws (such as Tax Law, Enterprise Law ...) which were capable of eliminating the motivation of investment enterprises and some areas of social security required high initial capital (such as agriculture, health ...) that affected the ability to mobilize capital and allocate resources of the "holding - subsidiary" company model and did not reflect the real results export of business.

In order to solve difficulties and problems around the Decree No. 20 / CP, on August 14, 2018, the Vietnam Real Estate Association on the basis of opinions of some members of Association had issued a Document No. 64 / CV- VNA and sent to the Government’s Prime Minister to propose amendments to the Decree 20 / CP. On November 8, 2018, the Government Office issued Official Letter No. 1690 / PC-VPCP to the Ministry of Finance for consideration and handling. However, many members of the Members' Association continued to send petitions to the Government’s Prime Minister - the relevant ministries and the Vietnam Real Estate Association. With this official letter, once again, the Vietnam Real Estate Association proposed to the Government’s Prime Minister the following contents:

- Proposed abolishing Clause 3, Article 8 of the Decree No. 20/2017 / ND-CP and studyingamendments and supplements to the Decree in accordance with current regulations, in line with international practices and practical business activities of enterprises in Vietnam.

- In the immediate future while waiting for the amendment and supplement of the Decree No. 20/2017 / ND-CP, we would like to request the Government to suspend the implementation of theDecree 20 / CP, specifically Clause 3, Article 8 of the Decree No. 20/2017 / ND -CP.