Ms. Luu Thi Hang's company signed a construction consulting service contract (including quantity surveying services: estimation, management and control of costs in construction projects, work quantity surveying, preparation of cost estimates, contract management, price negotiation, supervision of procurement of materials and supplies, and ensuring the project is completed on budget and meets required quality standards…) with a limited liability company, an export processing enterprise (EPE). According to Clause 2, Article 17 of Decree No. 181/2025/ND-CP detailing and guiding the implementation of the Value Added Tax (VAT) Law, services provided to organizations in a non-taxable zone (if consumed within the non-taxable zone) are subject to a 0% VAT rate. However, Clause 3, Article 17 of Decree No. 181/2025/ND-CP also stipulates that construction and installation activities abroad or in non-taxable zones are subject to a 0% VAT rate, leading to some differing interpretations between construction activities and construction consulting services. Regarding the construction consulting services provided by Ms. Hang's company to an export processing enterprise (EPE), she asks whether, in the case of a contract signed directly with the EPE, the company is eligible for the 0% VAT rate as stipulated in Clause 3, Article 17 of Decree No. 181/2025/ND-CP? Regarding this matter, the Ministry of Finance has the following opinion: Clause 1, Article 9 of the 2024 Value Added Tax Law stipulates the 0% VAT rate: "1. The 0% tax rate applies to the following goods and services: … b) Export services including: services provided directly to organizations and individuals abroad and consumed outside Vietnam; services provided directly to organizations in non-taxable zones and consumed within non-taxable zones, directly serving export production activities;". Article 17 of Government Decree No. 181/2025/ND-CP dated July 1, 2025, detailing the implementation of several articles of the Value Added Tax Law, stipulates a 0% VAT rate: "The 0% VAT rate applies to goods and services specified in Clause 1, Article 9 of the Value Added Tax Law. In which: … 2. Export services include: a) Services provided directly to organizations and individuals abroad and consumed outside Vietnam. In which: individuals abroad must meet the condition of being outside Vietnam during the period of service provision. b) Services provided directly to organizations in non-taxable zones and consumed within those zones, directly serving export production activities, including: services provided directly to organizations in non-taxable zones and consumed within those zones, directly serving export production activities." Import; transportation services, services provided to export processing enterprises (container handling services at ports, factories, warehouses; loading and unloading services at factories, ports, airports and related incidental costs such as: documentation fees, delivery fees, sealing fees, handling fees, packaging fees). An organization in the free trade zone is an organization with a business registration. … 5. Goods and services sold or provided to organizations in the free trade zone and consumed within the free trade zone, directly serving the export production activities stipulated in Clauses 1 and 2 of this Article, are goods and services consumed within the free trade zone to serve the export production activities of the organization in the free trade zone and not serving other activities not related to export production, except for the goods and services stipulated in Clause 4 of this Article. 6. The Ministry of Finance shall provide detailed regulations for this Article when necessary to perform its state management functions. We request that you compare this with legal regulations and base your actions on the actual records to ensure compliance.