Exports still down
According to the Vietnam Association of Seafood Exporters and Producers (VASEP), in the first 11 months of 2023, Vietnam's seafood exports reached 8.27 billion USD, down 19% over the same period last year. Of which, shrimp accounted for 38.1% of seafood export turnover with a value of 3.15 billion USD, down 22% over the same period in 2022.
For pangasius, by the end of November 2023, pangasius exports reached nearly 1.7 billion USD, still 26% lower than the same period last year. The average export price of pangasius decreased in major markets, especially the US and China, which has pulled the export value of pangasius down compared to 2022.
Mr. Ong Hang Van, Deputy General Director of Truong Giang Seafood Joint Stock Company, said that although the industry has recovered, the number of orders for pangasius fish is still very low and difficult to sell domestically. "If the market is still difficult at the end of the year, the industry's target of 10 billion USD may not be achieved," Mr. Van said.
With the current developments, VASEP forecasts that seafood exports for the whole year of 2023 are estimated to reach about 9 billion USD, down 18% compared to 2022. Of which, shrimp will earn about 3.4 billion USD, 21% less than last year, pangasius is estimated at 1.8 billion USD, down 25%, tuna is estimated at 850 million USD, down 15%; squid and octopus exports are estimated at 660 million USD, down 14%.
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| Seafood businesses are still facing many difficulties. |
Commenting on the export market in the coming time, according to Ms. Le Hang, Director of Communications of VASEP, China is likely to maintain a strong import trend in the last quarter of 2023 to compensate for the peak consumption season in December this year and January-February 2024. Shrimp demand in Southeast Asia and the Far East is expected to improve at the end of the year due to Christmas and New Year.
“Inflation is falling in all major European countries. However, traders are reluctant to start Christmas shopping as demand for crustaceans, including shrimp, remains weak,” Ms. Hang said.
Many problems need to be solved
Faced with market difficulties, in a recent document sent to the Government Office and the Advisory Council for Administrative Procedure Reform of Seafood Enterprises in November 2023, VASEP continued to point out many shortcomings that businesses in localities face.
The difficulties and problems raised by VASEP include four main issues: Inadequacies in the guidance on value-added tax (VAT) rates for seafood waste and by-products; inadequacies in issuing invoices for returned goods of businesses; difficulties in declaring VAT deductions for invoices of absconding or inactive businesses; too many inspection and examination teams each year.
Regarding the shortcomings, in the guidance on VAT rates for seafood waste and by-products, VASEP said that seafood processing companies have both frozen seafood products (not heated) and frozen products that have been steamed or boiled. The seafood raw materials used as input for these two products are the same. However, the VAT rates applied when selling scrap of the two types of products are different.
Therefore, the association recommends that the Ministry of Finance consider issuing a document guiding all local tax departments and enterprises so that all types of scrap, waste, and by-products of aquatic and seafood products (whether of primary or processed products) that have not been processed into other products or have only undergone normal primary processing are not required to declare and pay VAT at the commercial business stage.
In addition, the issuance of invoices for returned goods or returned purchases by businesses in localities is currently facing many difficulties. The reason is that although they are based on the same general regulations as Decree 123/2020/ND-CP dated October 19, 2020 of the Government regulating invoices and documents and Circular 78/2021/TT-BTC dated September 17, 2021 of the Ministry of Finance guiding the implementation of a number of articles of the Law on Tax Administration and Decree 123/2020/ND-CP, local tax departments are guiding businesses to implement in different, even contradictory ways.
For example, the Ho Chi Minh City Tax Department and the Binh Dinh Province Tax Department have issued official dispatches instructing businesses in this case to issue invoices to return purchased goods to the seller. However, the Quang Ninh Province Tax Department instructs businesses in this case to choose one of two ways to issue invoices: to issue invoices to return purchased goods or to issue invoices to return sold goods.
According to Mr. Truong Dinh Hoe, General Secretary of VASEP, in actual production and business activities, with businesses selling or delivering goods nationwide (buyers are supermarkets, restaurants, individuals, etc.), many invoices are generated every day. When the buyer discovers that the goods are defective or do not meet specifications, they will be allowed to return them by collecting them at the end of the week or returning them once a month (for convenience in transporting or delivering returned goods).
Mr. Hoe said that the buyer will notify the seller (supplier) and both parties will make a record of returning purchased goods. The record clearly states that the buyer issues an invoice to return the goods to the seller (which is both the basis for accounting/tax declaration/and a document for transporting goods on the road). There are also cases where the seller issues an adjustment invoice to reduce the sales invoice that has been made, if the record clearly shows that the seller made the invoice.
Meanwhile, according to the guidance documents of the local tax department, in this case, the buyer must cancel or withdraw all invoices and return the purchased goods that have been sent to the seller, and at the same time the seller must issue an adjustment invoice (returned goods) and give it to the buyer, then the parties must make a declaration to adjust all the information. This will first block the tax refund procedure and then the business may be fined for issuing incorrect invoices according to regulations.
From such difficulties, VASEP proposed that the Ministry of Finance consider issuing a unified guidance document for the relevant parties. Thereby, allowing the buyer and seller to choose the appropriate form of invoice for their business operations regardless of the procedure or form of return, provided that the tax declaration is consistent and reflects the true nature of the transaction between the two parties.
In addition, VASEP also recommends that State management agencies need to overcome the overlapping and duplication in inspection and examination activities; reduce unnecessary inspection and examination activities for enterprises, and strictly follow the direction in Directive No. 20/CT-TTg of the Government.
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