VietnameseCircular No. 40/2008/TT-BTC dated May 21, 2008 of the Ministry of Finance guiding the Government’s Decree No. 40/2007/ND-CP dated March 16, 2007, providing for customs valuation of imported goods and exported goods
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Circular No. 40/2008/TT-BTC dated May 21, 2008 of the Ministry of Finance guiding the Government’s Decree No. 40/2007/ND-CP dated March 16, 2007, providing for customs valuation of imported goods and exported goods
| Issuing body: | Ministry of Finance | Effective date: | Known Please log in to a subscriber account to use this function. Don’t have an account? Register here |
| Official number: | 40/2008/TT-BTC | Signer: | Do Hoang Anh Tuan |
| Type: | Circular | Expiry date: | Known Please log in to a subscriber account to use this function. Don’t have an account? Register here |
| Issuing date: | 21/05/2008 | Effect status: | Known Please log in to a subscriber account to use this function. Don’t have an account? Register here |
| Fields: | Customs , Export - Import |
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THE MINISTRY OF FINANCE --------- | SOCIALIST REPUBLIC OF VIET NAM Independence - Freedom - Happiness ---------- |
No. 40/2008/TT-BTC | Hanoi, May 21, 2008 |
CIRCULAR
GUIDING THE GOVERNMENTS DECREE No. 40/2007/ND-CP OF MARCH 16, 2007, PROVIDING FOR CUSTOMS VALUATION OF IMPORTED GOODS AND EXPORTED GOODS
Pursuant to June 14, 2005 Law No. 45/2005/QH11 on Import Tax and Export Tax;
Pursuant to June 29, 2001 Customs Law No. 29/2001/QH10, and June 14, 2005 Law No. 42/2005/QH11 Amending and Supplementing a Number of Articles of the Customs Law;
Pursuant to November 29, 2006 Law No. 78/2006/QH11 on Tax Administration;
Pursuant to the Governments Decree No. 77/2003/ND-CP of July 11, 2003, defining the functions, tasks, powers and organizational structure of the Ministry of Finance;
Pursuant to the Governments Decree No. 40/ND-CP of March 16, 2007, providing for customs valuation of imported goods and exported goods;
The Finance Ministry guides the implementation as follows:
Pursuant to June 29, 2001 Customs Law No. 29/2001/QH10, and June 14, 2005 Law No. 42/2005/QH11 Amending and Supplementing a Number of Articles of the Customs Law;
Pursuant to November 29, 2006 Law No. 78/2006/QH11 on Tax Administration;
Pursuant to the Governments Decree No. 77/2003/ND-CP of July 11, 2003, defining the functions, tasks, powers and organizational structure of the Ministry of Finance;
Pursuant to the Governments Decree No. 40/ND-CP of March 16, 2007, providing for customs valuation of imported goods and exported goods;
The Finance Ministry guides the implementation as follows:
Part I
GENERAL PROVISIONS
I. SCOPE OF REGULATION AND OBJECTS OF APPLICATION
1. This Circular provides for customs valuation for the purpose of calculating duties and making statistics on imported goods and exported goods.
2. Imported goods and export goods are objects of application of this Circular.
3. In case a treaty to which Vietnam is a contracting party contains provisions different from those of this Circular, that treaty prevails.
II. PRINCIPLES AND METHODS OF CUSTOMS VALUATION
1. Custom value to be used for the purpose of duty calculation (below referred to as dutiable value) is determined on the following principle and according to the following method:
a/ For exported goods, the dutiable value is the selling price of the exported goods at the border gate of exportation (FOB or DAF price), which is exclusive of international insurance cost (I) and international freight (F).
If no goods sale and purchase contract is available, the export dutiable value is the value declared by the customs declarant.
b/ For imported goods, the dutiable value is the actual price payable upon arrival of the goods at the first border gate of importation and determined by applying the six methods of dutiable value determination specified in Sections I thru VI, Part II of this Circular one after another and stopped immediately at any method by which the dutiable value can be determined.
The order of application of dutiable value-determining methods specified in Sections IV and V, Part II of this Circular may be changed when so requested in writing by custom declarants.
2. Customs value to be used for the purpose of making statistics (below referred to as statistical value) is determined on the following principle:
a/ For dutiable goods, the statistical value is determined based on the dutiable value already determined on the principle and by the method specified at Point b, Clause 1 of this Section.
b/ For non-dutiable goods, goods exempt from duty or considered for duty exemption, or of which the dutiable value cannot be determined under Point b, Clause 1 of this Section, the statistical value is the value declared by customs declarants on the following principle:
- For imported goods, the statistical value is the selling price of the goods at the first border gate of importation (CIF price);
- For exported goods, the statistical value is the selling price of the goods at the border gate of exportation (FOB or DAF price).
III. TIME OF CUSTOMS VALUATION AND DUTY PAYMENT TIME LIMIT
1. The time of customs valuation for imported goods or exported goods is the date a customs declarant registers a customs declaration of the imported goods or exported goods.
In case the dutiable value determination must be delayed, the time of dutiable value determination for imported goods is the date a customs office or customs declarant successfully determines the dutiable value under this Circular.
2. Duty payment time limit:
a/ For differences between duty amounts assessed by customs offices and tax amounts declared or calculated by duty payers themselves after the customs clearance of their goods, this time limit is 10 (ten) days after customs offices sign decisions on duty assessment.
b/ For other cases, the duty payment time limit complies with the provisions of Clauses 3, 4 and 5, Article 52 of the Tax Administration Law.
IV. INTERPRETATION OF TERMS
Terms and expressions referred to in this Circular are construed as follows:
1. Goods purchase and sale contract means a written agreement on goods purchase and sale made for the purpose of importing goods into Vietnam, whereby the seller is obliged to deliver goods and transfer the ownership of goods to the purchaser and receive money; and the purchaser is obliged to pay money to the seller and receive goods. Agreements made in the form of telegraph or e-mail or by telex or fax or another form of electronic communication and printed out on papers are also regarded as written agreements.
2. Purchase commission means a sum of money paid by a purchaser to an agent for representing the purchaser in purchasing imported goods at the most reasonable price.
3. Sale commission means a sum of money paid by a seller to an agent for representing the seller in selling exported goods to purchasers.
4. Brokerage commission means a sum of money payable by a purchaser or seller or both to a broker that acts as an intermediary in an imported goods sale and purchase transaction.
5. Royalty and licensing fee means a sum of money payable by a purchaser directly or indirectly to the intellectual property rights holder or a person authorized or licensed by the intellectual property rights holder for the use of intellectual property rights. For example, a sum of money paid for a patent, layout design copyright, trademark, mark license, copyright or production license.
6. Different goods are regarded as having values which closely approximate to one another if the value disparity between them is caused by the following objective factors:
- Their nature or characteristics of their manufacturing industries;
- Their seasonality;
- Their insubstantially commercial distinctiveness.
Upon considering the approximate equality of the two values, it is necessary to subject them to the same purchase and sale condition.
7. Identical imported goods means goods which are the same in all respects, including:
- Physical characteristics, such as surface, composition materials, method of manufacture, functions, utility; mechanical, physical and chemical characteristics;
- Quality;
- Reputation of marks;
- They are made in the same country or by the same manufacturer or licensed manufacturer.
Imported goods which basically satisfy the conditions for being regarded as identical imported goods but have minor differences in appearance, such as color, size and design, which do not affect their values, are still regarded as identical.
Imported goods are not regarded as identical if in the process of manufacturing any of these goods, technical designs, construction designs, development plans, fine-art designs, design drawings, charts, sketches or similar products or services, which are made in Vietnam and supplied free of charge by the purchaser to the seller, are used.
8. Similar imported goods means goods which are not alike in all respects but have the same substantial characteristics, including:
- They are made of equivalent raw materials and materials or by the same method of manufacture;
- They have the same function or utility;
- They are of equal quality;
- They are commercially interchangeable, for example: a purchaser accepts goods in substitution for similar goods;
- They are made in the same country or by the same manufacturer or licensed manufacturer and imported into Vietnam.
Imported goods are not regarded as similar if in the process of manufacturing any of these goods, technical designs, construction designs, fine-art designs, development plans, design drawings, charts, sketches or similar products or services, which are made in Vietnam and supplied free of charge or at reduced cost by the purchaser to the seller, are used.
9. Imported goods of the same class or category means goods belonging to a group or a frame group of goods manufactured by the same industry or in the same domain, including identical imported goods and similar imported goods.
For example: Construction steel products, including steel rods, wound coils and sections (U, I or V shape) manufactured by the steel industry, are regarded as goods of the same category.
- In the method of determining the dutiable value based on the deductible value, imported goods of the same class or category may be goods imported from all other countries into Vietnam, regardless of their origin.
- In the method of determining the dutiable value based on the computed value, imported goods of the same class or category must be imported goods of the same origin with the goods being valued.
10. First border gate of importation means the port of destination stated in the bill of lading. For road, railway or river channel transportation, the first border gate of importation is the port of destination stated in the contract.
Part II
DUTIABLE VALUE OF IMPORTED GOODS
I. DETERMINING THE DUTIABLE VALUE ON THE BASIS OF THE TRANSACTION VALUE
The dutiable value of imported goods must be first of all determined on the basis of the transaction value.
Transaction value is the price actually paid or payable by the purchaser to the seller for the purchase of an imported goods and adjusted under the provisions of Section VII, Part II of this Circular.
The price actually paid or payable is determined to be the total sum of money already paid or payable by the purchaser directly or indirectly to the seller for the purchase of imported goods.
1. The transaction value is applied if the following conditions are fully satisfied:
a/ There are no restrictions on purchasers right to dispose of or use the goods after they are imported other than the following restrictions which:
a.1/ Are imposed by Vietnamese law, such as provisions requiring imported goods to be labeled in Vietnamese, on goods subject to conditional import or a form of inspection before customs clearance, etc.
a.2/ Limit the places where the goods may be sold; or,
a.3/ Do not affect the value of the goods.
These restrictions constitute one or several factors directly or indirectly related to imported goods but do not increase or decrease prices actually paid for these goods.
For example: The seller requests the purchaser not to sell or display imported goods before the seller markets these goods.
b/ The price or sale is not subject to some conditions or payments for which a value cannot be determined for the goods being valued.
For example:
- The seller fixes the price of the imported goods on condition that the purchaser will purchase a certain quantity of other goods.
- The price of the imported goods depends on the prices of other goods which will be sold by the importer to the exporter.
- The price of the imported goods is fixed on the basis of a mode of payment extraneous to the imported goods, for example: imported goods are semi-finished products supplied by the seller to the purchaser on condition that the seller will receive back a certain quantity of finished products manufactured from these imported semi-finished products.
In case the sale or price of the goods is dependent on one or several conditions but the purchaser possesses objective and valid documents for the determination of the pecuniary impact of such dependence, this condition shall still be regarded as being met. Upon determination of the dutiable value, the money amount reduced due to the dependences impact must be added to the transaction value.
c/ After reselling, transferring or using imported goods, the purchaser is not required to additionally pay any sum of money from the proceeds of the disposal of imported goods, except for the additions specified at Point e, Clause 2, Section VII, Part II of this Circular.
d/ The purchaser and seller have no special relationship or have a special relationship which does not influence the transaction value. The consideration of the special relationships influence on the transaction value is guided in Clause 3 of this Section.
2. The transaction value consists of the following:
a/ The purchase price stated in invoices:
In case the purchase price stated in invoices includes discounts for the lot of imported goods, these discounts must be subtracted in determining the dutiable value on the conditions that the discount policy is stated in writing before the goods are loaded onto a means of transport, there are lawful and valid data and documents for excluding these discounts from the invoice price, and those documents must be submitted together with the customs declaration.
Types of discount include:
- Discount based on the commercial level of the goods purchase and sale transaction;
- Discount based on the quantity of purchased and sold goods;
- Discount based on the mode and time of payment;
Discounts are accepted to be deducted upon determination of the dutiable value on condition that they conform to international commercial practice.
If goods for which there are contractual discounts are imported in different lots (with different declarations), these discounts may be considered and accepted only after the importing enterprise submits the manifest and documents proving that the importation and payment for the whole contract have been completed. The customs office at which the enterprise opens its customs declarations shall check relevant records and documents submitted by the enterprise to prove that discounts have been actually given.
b/ Adjustments under the guidance in Section VII, Part II of this Circular.
c/ Sums of money payable by the purchaser but not yet included in the purchase price stated in invoices, including:
- Prepaid amounts, advances and deposits for the manufacture, purchase, sale, transportation or insurance of goods.
- Indirect payments to the seller, such as sums of money paid by the purchaser to a third party at the request of the seller or sums of money paid by debt clearing.
3. Determination of special relationships influence on transaction value:
a/ If the purchaser and the seller have a special relationship which does not influence the transaction value, the customs declarant shall report this relationship and determine the dutiable value according to the transaction value.
b/ If the customs office, based on available information, suspects that the special relationship has influenced the transaction value, it shall promptly notify in writing the customs declarant of grounds for its suspicion.
c/ The customs office shall create favorable conditions for the customs declarant to explain and supply more information in order to clarify the special relationship between the purchaser and the seller which does not influence the transaction value of the imported goods specified at Point d of this Clause.
Past 30 working days after receiving the customs offices notice, if the customs declarant fails to explain and supply more relevant information, the customs office shall determine the dutiable value of the imported goods lot on the principles and methods of dutiable value determination specified in Sections I thru VI, Part II of this Circular.
d/ The special relationship between the purchaser and seller is considered not influencing the transaction value if it satisfies one of the following two conditions:
d.1/ Despite the special relationship, the purchase and sale transaction is still conducted between the seller and purchaser like purchase and sale transactions with purchasers who have no special relationship with the seller.
- Example 1:
+ The purchase and sale price of the imported goods has been negotiated and agreed upon in the commercial contract in a manner consistent with the normal pricing negotiation and agreement practices of that goods line or with the way the seller offers the goods purchase and sale price to other purchasers who have no special relationship with the seller.
+ The purchase and sale price of the imported goods is inclusive of also all costs and a profit corresponding to overall profit from the sale of goods of the same class or category.
The customs office shall examine the way the purchaser and the seller have organized the purchase and sale relationship and the manner of negotiation to reach the declared price before reaching a conclusion on whether the declared value has been influenced by the special relationship.
d.2/ The transaction value closely approximates to any of the following values of the goods lot exported to Vietnam on the same day or within 60 days (of the calendar year) before and after the date of exportation of the goods lot being valued:
- The dutiable value determined on the basis of the transaction value of identical or similar imported goods sold to other importers that have no special relationship with the exporter (the seller);
- The dutiable value of identical or similar imported goods determined on the basis of the deductible value specified in Section IV, Part II of this Circular;
- The dutiable value of identical or similar imported goods determined on the basis of the computed value specified in Section V, Part II of this Circular.
d.3/ The above dutiable values are used for comparison purposes only and the dutiable value of identical or similar imported goods must be adjusted to the same condition with the imported goods being valued:
- Adjustment to the same purchase and sale condition: The adjustment of the dutiable value of identical or similar imported goods to the same purchase and sale condition with the goods lot being valued complies with the guidance of Point b, Clause 2, Section III, Part II of this Circular.
- Adjustment of additions or reductions under the guidance of Section VII, Part II of this Circular.
4. Determination of the dutiable value of imported goods being carrier media bearing software for data processing devices:
a/ The dutiable value of imported goods being carrier media bearing software is the value actually paid or payable for these carrier media, exclusive of the value of the software they bear, on condition that the softwares invoice value is separated from the carrier medias invoice value.
The dutiable value of carrier media is inclusive of the purchase price stated in invoices and expenses for recording or installation of the software in the media.
Software referred to herein means data, programs or instructions which are expressed in the form of commands, codes, diagrams or any other form and can make data processing devices in which they are installed capable of performing a task or achieving a specified result (for example: software programs, instructions describing digitalized information programs). Audiovisual sequences in feature films or video recordings are not regarded as software under this regulation.
Carrier media means floppy disks, compact disks, magnetic tapes or cards or any objects capable of storing information, which are used as devices for temporarily storing or transmitting software. To be used, software must be transmitted to, installed in or integrated into data processing devices.
Carrier media mentioned herein exclude integrated circuits, microchips, semi-conductor circuits and the like or parts affixed on circuit boards or devices.
b/ The provisions of Point a of this Clause do not apply to the determination of the dutiable value of devices, machines or equipment bearing imported software falling into one of the following cases:
- Software is recorded, installed or integrated in imported goods other than carrier media or in hardware of machines or equipment.
- The value actually paid for imported software is one of the additions specified in Section VII, Part II of this Circular.
5. Documents to be submitted:
- Customs dossier as specified;
- Other documents relevant to the dutiable value determination.
II. DETERMINING THE DUTIABLE VALUE BASED ON THE TRANSACTION VALUE OF IDENTICAL IMPORTED GOODS
If the dutiable value of imported goods cannot be determined on the basis of their transaction value guided in Section I, Part II of this Circular, it may be determined on the basis of the transaction value of identical imported goods.
The method of determining the dutiable value of imported goods on the basis of the transaction value of identical imported goods is guided in Section III of this Part, in which the phrase similar imported goods should be replaced by the phrase identical imported goods.
III. DETERMINING THE DUTIABLE VALUE ON THE BASIS OF THE TRANSACTION VALUE OF SIMILAR IMPORTED GOODS
1. Determining the dutiable value:
If the dutiable value of imported goods cannot be determined according to the methods guided in Sections I and II, Part II of this Circular, it may be determined on the basis of the transaction value of similar imported goods on condition that these similar imported goods have been accepted by customs offices for the determination of the dutiable value based on the transaction value and have the same purchase and sale condition and export time condition with the imported goods being valued under the guidance in Clause 2 of this Section.
If there is no similar imported goods lot with the same purchase and sale condition with the imported goods being valued, other similar imported goods lots with different purchase and sale conditions may be chosen, provided that adjustments must be made to the same purchase and sale condition.
2. Conditions on similar imported goods lots to be chosen:
To be chosen, similar imported goods lot must satisfy the following conditions:
a/ Export time condition:
The similar imported goods lot must be exported to Vietnam on the same day or within 60 days before or after the date of exportation of the imported goods being valued.
b/ Purchase and sale conditions:
b.1/ Condition on commercial level and quantity:
b.1.1/ The similar imported goods lot must have the same condition on commercial level and quantity with the imported goods lot being valued.
b.1.2/ If no imported goods lot mentioned at Item b.1.1 is found, an imported goods lot at the same commercial level but in a different quantity may be chosen and the transaction value of these similar imported goods must later be adjusted to the same quantity with the goods lot being valued.
b.1.3/ If no imported goods lot mentioned at Items b.1.1 and b.1.2 is found, an imported goods lot at a different commercial level but in the same quantity may be chosen and the transaction value of this similar imported goods lot must later be adjusted to the same commercial level with the goods lot being valued .
b.1.4/ If no imported goods lot mentioned at Items b.1.1, b.1.2 and b.1.3 is found, an imported goods lot at a different commercial level and in a different quantity may be chosen and the transaction value of this similar imported goods lot must later be adjusted to the same commercial level and quantity with the goods lot being valued.
b.2/ Condition on distance and mode of transport, and insurance:
The similar imported goods lot must have the same distance and mode of transport, or have been adjusted to the same distance and mode of transport with the goods lot being valued.
If there is a significant difference in insurance cost between two lots, the similar imported goods lot must be adjusted to the same insurance condition with the goods lot being valued.
c/ If the method of determining the dutiable value based on the transaction value of similar imported goods is applied but no similar imported goods manufactured by the same manufacturer or licensed manufacturer is found, goods manufactured by other manufacturers and of the same origin may be considered and chosen.
d/ In case of determining the dutiable value determination according to this method, if more than one transaction value of similar imported goods are found, the dutiable value is the lowest transaction value after similar imported goods have been adjusted to the same purchase and sale condition with the goods lot being valued.
During the time of carrying out customs procedures, if there is insufficient information for choosing imported goods identical or similar to imported goods being valued, the dutiable value of imported goods must not be determined under the guidance in Section II or Section III, Part II of this Circular but must be determined according to the next method.
3. Documents to be submitted:
a/ If applying the method of determining the dutiable value based on the transaction value of similar imported goods, customs declarants shall submit, apart from customs dossiers as specified, enterprise-certified copies of the following documents to customs offices:
- Customs declaration and declaration of the value of similar imported goods;
- Transport contract of similar imported goods (in case of adjustment of freight);
- Insurance contract of similar imported goods (in case of adjustment of insurance cost);
- Commercial contract and commercial invoice of similar imported goods, exported goods price lists of the foreign manufacturer or seller (in case of adjustment of quantity and commercial level);
- Other lawful and valid documents and vouchers necessary and relevant to the dutiable value determination (when necessary).
b/ When applying the method of determining the dutiable value based on the transaction value of similar imported goods, customs offices shall base themselves on information available at customs offices where the dutiable value is determined and documents and vouchers supplied by customs declarants for determining the dutiable value.
IV. DETERMINING THE DUTIABLE VALUE ON THE BASIS OF THE DEDUCTIBLE VALUE
1. Determining the dutiable value:
If the dutiable value of imported goods cannot be determined according to the methods guided in Sections I, II and III, Part II of this Circular, it may be determined on the basis of the deductible value and based on the unit price at which imported goods, identical or similar imported goods are sold on Vietnams domestic market minus (-) reasonable expenses for and profits earned from the sale of the imported goods.
This method is not applied if goods chosen for determining the unit price fall into one of the following cases:
- They have not yet been sold on the domestic market or their sales have not yet been reflected on accounting books and documents under Vietnams accounting law;
- They are involved in assists provided by any person as specified at Item d.1, Point d, Clause 2, Section VII, Part II of this Circular.
2. Conditions on a unit price on the Vietnamese market to be chosen:
a/ It must be the unit price at which imported goods being valued, identical or similar imported goods are sold in the conditions as when imported.
b/ It must be the unit price at which the greatest aggregate quantity of goods is sold, which is sufficient for establishing that unit price. Goods are sold on the earliest day after the importation but before the expiration of 90 days after the date of importation of the goods being valued. The domestic purchaser and the seller have no special relationship.
Example 2: Goods lot A consists of many goods items, including item B being valued according to the deductive method. Goods lot A was imported on January 1, 2005. A goods lot consisting of a goods item identical to goods item B was imported earlier and sold to many domestic purchasers at different prices and at different times as follows:
Unit price | Quantity/sale | Selling time | Total quantity |
VND 900/unit | 50 units | March 28, 2005 | 100 units |
30 units | January 15, 2005 | ||
20 units | March 3, 2005 | ||
VND 800/unit | 200 units | January 20, 2005 | 450 units |
250 units | February 12, 2005 | ||
Total: | 550 units |
In the above example, the sale unit price chosen for deduction is VND 800/unit corresponding to the greatest quantity of units sold (450) and sufficient for establishing the unit price. This unit price satisfies the conditions on a unit price to be chosen, including:
- The greatest aggregate quantity (450).
- The sale time is within 90 days after the date of importation.
3. Deduction principle:
The determination of deductions must be based on accounting data and available lawful and valid accounting documents and recorded and reflected under Vietnamese accounting standards.
Deductions must be those allowed to be accounted as reasonable and lawful expenses of enterprises under the Vietnamese accounting law.
4. Deductions to be made from the sale unit price:
Deductions to be made from the sale unit price are reasonable expenses for and profits earned from the sale of goods on the Vietnamese market, including:
a/ Costs of transport and insurance and expenses for other activities related to the transportation of goods after their importation, specifically as follows:
a.1/ Costs of transport and insurance and expenses for other activities related to the transportation of goods incurred during the time of transportation from the first border gate to the importers warehouse or the place of delivery in inland Vietnam;
a.2/ Costs of transport and insurance and expenses for other activities related to the transportation of goods incurred during the time of transportation from the importers warehouse in inland Vietnam to the place of goods sale, in case the importer bears these costs and expenses.
b/ Taxes, charges and fees payable in Vietnam upon the importation and sale of the imported goods on the domestic market of Vietnam.
c/ Commissions or general expenses and profits related to the sale of the imported goods in Vietnam.
c.1/ In case the importer is a sale agent for a foreign trader, the commission will be deducted. If that commission is inclusive of expenses specified at Points a and b of this Clause, these expenses must not be further deducted.
c.2/ In case of importation by the mode of definite purchase and sale, general expenses and profits shall be deducted: General expenses and profits must be taken as a whole upon determining the deductible value. The determination and allocation of general expenses and profits to an imported goods lot must comply with Vietnamese accounting regulations and standards.
General expenses include direct and indirect expenses for the importation and sale of gsoods on the domestic market, such as expenses for marketing goods, expenses for storage and preservation of goods before sale, expenses for management of the importation and sale of goods, etc.
Bases for determining deductions are data recorded and reflected on accounting vouchers and books of the importer and compliant with Vietnamese accounting regulations and standards. These data must be consistent with those obtained from activities of purchasing and selling imported goods of the same class or category in Vietnam.
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