The Tax Department of Lao Cai province responded to this problem as follows:

Pursuant to Point c, Clause 3, Article 10 of Circular No. 96/2015/TT-BTC dated June 22, 2015 of the Ministry of Finance guiding CIT in Decree No. 12/2015/ND-CP dated February 12 2015 of the Government detailing the implementation of the Law amending and supplementing a number of articles of the tax laws and amending and supplementing a number of articles of the tax decrees and amending and supplementing a number of articles of the Circular Circular No. 78/2014/TT-BTC dated June 18, 2014, Circular No. 119/2014/TT-BTC dated August 25, 2014, Circular No. 151/2014/TT-BTC dated October 10, 2014 of The Ministry of Finance stipulates:

"c) For enterprises currently enjoying CIT incentives under the category of newly established enterprises from investment projects, only income from production and business activities that satisfy the conditions for investment incentives stated in certificate of enterprise registration or certificate of initial investment of the enterprise.

For enterprises currently operating in production and business, if there is a change in their business registration certificate or investment certificate but such change does not change the project's satisfaction of tax incentives. According to regulations, the enterprise will continue to enjoy tax incentives for the rest of the time or incentives under the expanded investment category if it meets the preferential conditions as prescribed.

Based on the above regulations, the company was established in 2019 at the address Nam Cuong Ward, Lao Cai city (in an area with difficult socio-economic conditions). In August 2022, the Company moved its business location to Lao Cai ward, Lao Cai city (in the border economic zone), in 2022, her company will not be entitled to CIT incentives according to the new address.

The company can only continue to enjoy tax incentives according to the previous regulations for the remaining time if the company meets the tax incentives of that project.