Based on Article 1 and Article 7 of Circular No. 103/2014/TT-BTC and current Corporate Income Tax laws: If a Company entered into a long-term loan agreement with its overseas parent company in 2014, and the agreement states that the principal and interest will be repaid in a lump sum after 10 years, the parent company is subject to contractor tax in Vietnam on income from loan interest as prescribed.
If the parent company writes off the loan interest debt, and the Company does not incur loan interest payments to the parent company, then the Company is not required to declare and pay foreign withholding tax on behalf of the parent company. The loan interest expense that the Company deducts in advance each year corresponding to the written-off loan interest must be recorded as other income to determine taxable income as prescribed.