Cuộc Chơi Chưa Bình Đẳng (Phần 2)

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Gần đây, Chính phủ đã ban hành Nghị định 34/2008/NĐ-CP ngày 25/03/2008 và được sửa đổi, bổ sung bởi Nghị định 46/2011/NĐ-CP ngày 17/06/2011 siết chặt hơn nữa việc tuyển dụng và quản lý người lao động nước ngoài (“NLĐNN”) làm việc tại Việt Nam nhằm mục đích tăng việc làm, tạo cơ hội chuyển giao kiến thức, kinh nghiệm, nghiệp vụ cho người lao động Việt Nam. Tuy nhiên, các doanh nghiệp tại Việt Nam nói chung và các doanh nghiệp có vốn đầu tư nước ngoài, chi nhánh và văn phòng đại diện của các công ty nước ngoài tại Việt Nam nói riêng vẫn có khuynh hướng tiếp tục tuyển dụng NLĐNN làm việc cho họ tại Việt Nam mặc dù một số vị trí công việc người lao động Việt Nam có thể đảm trách.

Có một vài lý do cho khuynh hướng này. Một trong số đó là có một số vị trí quản lý, kỹ thuật trong doanh nghiệp đặc biệt là doanh nghiệp hoạt động kinh doanh trong một số ngành, nghề còn mới hay chưa phổ biến ở Việt Nam mà thực tế là người lao động Việt Nam chưa thể đảm trách được. Một lý do khách quan khác là sự tương đồng về văn hóa và ngôn ngữ giao tiếp mà một số doanh nghiệp có vốn đầu tư nước ngoài, chi nhánh, văn phòng đại diện của công ty nước ngoài tại Việt Nam có khuynh hướng thích tuyển dụng người của quốc gia họ (chẳng hạn người Nhật thường thích làm việc với người Nhật). Một lý do khác nữa cũng không kém phần quan trọng là khuynh hướng sính ngoại của một số doanh nghiệp Việt Nam, muốn thuê một vài “ông tây” vào làm việc cho công ty thêm phần hoành tráng. Qua bài viết này, tác giả cũng muốn giới thiệu thêm một lý do nữa đó là trong một số trường hợp chi phí thuế và bảo hiểm có liên quan đến việc thuê NLĐNN lại rẻ hơn chi phí tương tự phải trả cho việc thuê mướn người lao động Việt Nam!

Theo quy định của Luật Thuế thu nhập cá nhân (“TNCN”) và các văn bản hướng dẫn hiện hành thì bất kỳ người Việt Nam hay người nước ngoài nào mà có thu nhập chịu thuế đều phải đóng thuế TNCN theo các biểu thuế giống nhau. Thoạt nghe thì có vẻ như Luật Thuế TNCN bình đẳng hơn so với Pháp lệnh Thuế thu nhập dành cho người có thu nhập cao trước đây khi Pháp lệnh đã áp dụng hai biểu thuế khác nhau cho người nước ngoài và người Việt Nam. Tuy nhiên, trên thực tế thì Luật Thuế TNCN cũng lại có một số điều khoản ưu ái hơn cho NLĐNN. Đó là một số loại thu nhập từ tiền lương, tiền công của NLĐNN sẽ không phải tính vào thu nhập chịu thuế, bao gồm khoản trợ cấp chuyển vùng một lần, khoản tiền mua vé máy bay khứ hồi do đơn vị sử dụng lao động chi trả hộ cho NLĐNN về phép mỗi năm một lần, tiền học phí cho con của NLĐNN học tại Việt Nam theo bậc học phổ thông do đơn vị sử dụng lao động chi trả hộ[1] hay một số khoản thu nhập dù bị chịu thuế nhưng lại theo mức thu nhập thấp hơn mức thu nhập thực tế mà họ nhận được (đó là tiền thuê nhà mà đơn vị sử dụng lao động chi trả hộ sẽ phải chịu thuế ở mức tối đa bằng 15% của tổng thu nhập chịu thuế bất kể khoản tiền thuê nhà phải trả là bao nhiêu)[2].

Bên cạnh đó, Luật Thuế TNCN cũng có sự phân biệt trong cách đánh thuế TNCN giữa “cá nhân cư trú” và “cá nhân không cư trú”. Trong khi cá nhân cư trú đóng thuế theo biểu thuế lũy tiến từng phần (từ mức 5% đến 35%) trên thu nhập toàn cầu thì cá nhân không cư trú chỉ phải đóng thuế theo mức thuế suất 20% đối với các khoản thu nhập phát sinh tại Việt Nam. Khái niệm “cá nhân cư trú” được định nghĩa là những người có mặt tại Việt Nam từ 183 ngày trở lên tính trong một năm dương lịch hoặc trong 12 tháng liên tục kể từ ngày đầu tiên có mặt tại Việt Nam hoặc có nơi ở thường xuyên tại Việt Nam theo một trong hai trường hợp sau: (i) Có nơi ở đăng ký thường trú theo quy định của pháp luật về cư trú; hoặc (ii) có nhà thuê để ở tại Việt Nam theo quy định của pháp luật về nhà ở, với thời hạn của hợp đồng thuê từ 90 ngày trở lên trong năm tính thuế. Những người nào mà không thỏa mãn quy định trên thì được coi là cá nhân không cư trú[3].

Theo tiêu chí trên thì tuyệt đại đa số người Việt Nam đều được xem là cá nhân cư trú vì họ thường có một nơi ở đăng ký thường trú tại Việt Nam trong khi NLĐNN thì thông thường sẽ xét vào tiêu chí trên để xác định xem họ là cá nhân cư trú hay cá nhân không cư trú của Việt Nam. Do NLĐNN được xét để đóng thuế theo một trong hai phương thức đánh thuế khác nhau nên nếu thu nhập từ tiền lương, tiền công của họ càng cao thì họ càng có khuynh hướng muốn đóng thuế theo mức cố định là 20% trên thu nhập phát sinh tại Việt Nam như là cá nhân không cư trú hơn là với tư cách cá nhân cư trú khi phải đóng thuế theo mức thuế lũy tiến từng phần mà mức cao nhất lên đến 35% thu nhập toàn cầu của họ. Đây cũng là một lợi thế nữa cho phép NLĐNN tính toán để chọn tư cách pháp lý về thuế để giảm thiểu số thuế phải đóng tại Việt Nam trong khi người lao động Việt Nam trong đa số các trường hợp lại không có quyền chọn lựa này.

Cũng dựa vào tiêu chí cá nhân không cư trú, một số NLĐNN cố gắng thương lượng với đơn vị sử dụng lao động để tách hợp đồng lao động của họ thành hai hợp đồng nhỏ, một phần nhỏ thu nhập (một con số tương đối hợp lý) được ghi vào hợp đồng lao động mà họ ký với đơn vị sử dụng lao động tại Việt Nam và một phần lớn thu nhập trong một hợp đồng lao động khác mà họ sẽ ký với công ty mẹ ở nước ngoài. Họ cũng sẽ cố gắng lưu lại Việt Nam không quá 183 ngày trong một năm dương lịch bằng việc bay đi, bay về làm việc giữa công ty mẹ ở nước ngoài và công ty con tại Việt Nam. Vì thế, họ sẽ được xem như là cá nhân không cư trú của Việt Nam và chỉ có phần thu nhập phát sinh tại Việt Nam (phần nhỏ) phải chịu thuế tại Việt Nam.

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Ngoạn mục hơn, nếu NLĐNN là cá nhân cư trú của một trong những nước đã ký hiệp định tránh đánh thuế hai lần với Việt Nam (“Hiệp Định”) (Việt Nam hiện nay đã ký Hiệp Định với hơn 60 quốc gia) thì theo quy định trong đa số các Hiệp Định, tiền công do một đối tượng cư trú của một nước ký kết Hiệp định (ví dụ như Singapore) thu được từ lao động làm công tại nước ký kết kia (ví dụ như Việt Nam) sẽ chỉ bị đánh thuế tại Singapore mà thôi nếu – (i) người nhận tiền công có mặt tại Việt Nam trong một thời gian hay nhiều thời gian gộp lại không quá 183 ngày trong năm dương lịch; và (ii) đơn vị sử dụng lao động không phải là đối tượng cư trú tại Việt Nam; và (iii) số tiền công không phải phát sinh tại một cơ sở thường trú hoặc một cơ sở cố định mà đơn vị sử dụng lao động có tại Việt Nam. Vậy nên, một số NLĐNN sẽ cố gắng không lưu lại Việt Nam quá 183 ngày trong một năm dương lịch cũng như đơn vị sử dụng lao động cố gắng không có cơ sở thường trú tại Việt Nam đồng thời với việc công ty mẹ ở nước ngoài chịu chi phí tiền lương để thu nhập từ tiền lương, tiền công của NLĐNN không phải chịu thuế TNCN tại Việt Nam.

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Cũng có một vài trường hợp do mức thuế TNCN của Việt Nam khá cao so với một số nước trong khu vực chẳng hạn như Singapore, đơn vị sử dụng lao động và NLĐNN sẽ thương lượng để tách khoản tiền lương, tiền công của NLĐNN thành hai phần là tiền lương và tiền thưởng (có thể gọi là tiền thưởng nhận việc mới hay tiền thưởng hoàn thành công việc). Tiền lương, theo đó, sẽ được kê khai và trả thuế đầy đủ tại Việt Nam nhưng khoản tiền thưởng thì không trả cho NLĐNN trong thời gian đang làm việc tại Việt Nam mà sẽ trả trước khi họ đến Việt Nam nhận công việc (tiền thưởng nhận việc mới) hoặc là chờ cho đến khi NLĐNN rời Việt Nam về làm việc lại cho công ty mẹ ở nước ngoài rồi thì công ty mẹ mới trả (tiền thưởng hoàn thành công việc). Hàng tháng, công ty mẹ vẫn tạm ứng đều đặn cho NLĐNN một phần số tiền thưởng này vào tài khoản của họ ở nước ngoài (nhưng số tiền này không được thể hiện trong sổ sách kế toán của công ty tại Việt Nam và cũng không được khai báo cơ quan thuế của Việt Nam) . Số tiền thưởng hoàn thành công việc sẽ được chi trả sau khi NLĐNN không còn ở Việt Nam nữa và được trừ vào phần đã được tạm ứng hàng tháng trước đây và khoản tiền thưởng này có thể được xem là thu nhập không phát sinh tại Việt Nam và không phải đóng thuế tại Việt Nam mà có thể sẽ đóng thuế ở nước ngoài nơi họ là cá nhân cư trú với mức thuế thấp hơn mức thuế ở Việt Nam. Dù Bộ Tài Chính và Tổng Cục thuế Việt Nam trong các công văn hướng dẫn thuế gần đây có quy định rõ các khoản thu nhập có bản chất như vậy sẽ phải chịu thuế tại Việt Nam dù có được trả ở nước ngoài sau thời gian lao động tại Việt Nam nhưng nếu đơn vị sử dụng lao động và NLĐNN thông đồng với nhau không khai báo thì cơ quan thuế địa phương của Việt Nam cũng bó tay vì họ không có thông tin để kiểm tra tại Việt Nam và trong sổ sách kế toán của đơn vị sử dụng lao động tại Việt Nam lại không thể hiện các khoản chi phí tiền thưởng này.

Ngoài thuế TNCN, còn có một thuận lợi không nhỏ khác cho đơn vị sử dụng lao động khi thuê mướn NLĐNN làm việc tại Việt Nam là NLĐNN không buộc phải đóng bảo hiểm xã hội và bảo hiểm thất nghiệp bắt buộc như người lao động Việt Nam. Mức đóng bảo hiểm xã hội[4] theo quy định cho năm 2012 là 24% mức tiền lương, tiền công tháng đóng bảo hiểm xã hội của người lao động (17% dành cho người sử dụng lao động và 7% dành cho người lao động) và 26% trong năm 2014 (18% dành cho người sử dụng lao động và 8% dành cho người lao động). Bên cạnh đó, từ năm 2009, người lao động và người sử dụng lao động còn phải đóng bảo hiểm thất nghiệp[5] là 2% (1% dành cho đơn vị sử dụng lao động và 1% dành cho người lao động). Đây thật sự không phải là một khoản chi phí nhỏ cho đơn vị sử dụng lao động. Bên cạnh đó, NLĐNN cũng không buộc phải tham gia công đoàn trong doanh nghiệp nên cũng sẽ không phải đóng lệ phí công đoàn tương đương với 1% tiền lương trên hợp đồng lao động của họ[6].

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Sau cùng, trong một số trường hợp mà thu nhập từ tiền lương, tiền công của NLĐNN quá cao thì đơn vị sử dụng lao động và NLĐNN còn thương lượng để NLĐNN ra nước ngoài (thường là ở các thiên đường thuế như BVI hay Carmay Island) thành lập công ty (tạm gọi là “Công ty BVI”) và công ty BVI này sẽ ký hợp đồng cung cấp dịch vụ (thí dụ như hợp đồng dịch vụ tư vấn quản lý) với đơn vị sử dụng lao động tại Việt Nam. Theo các hợp đồng này, công ty BVI sẽ cử nhân viên của họ chính là NLĐNN vào cung cấp dịch vụ theo hợp đồng đã ký với đơn vị sử dụng lao động tại Việt Nam. NLĐNN này sẽ nhận tiền lương rất thấp và do đó cũng sẽ đóng thuế thấp tại Việt Nam. Số tiền phí dịch vụ mà đơn vị sử dụng lao động tại Việt Nam trả cho công ty BVI thường sẽ chỉ phải đóng thuế nhà thầu tại Việt Nam (mức thuế thấp) nhưng sẽ không phải đóng thuế thu nhập doanh nghiệp ở BVI và có thể được chia trọn vẹn cho cho cổ đông chính là NLĐNN đó dưới hình thức là cổ tức. Nếu NLĐNN là cá nhân cư trú của Việt Nam thì chỉ phải đóng 5% thuế TNCN trên tiền cổ tức còn nếu cá nhân NLĐNN đó là cá nhân không cư trú thì số tiền cổ tức này sẽ không chịu thuế TNCN tại Việt Nam vì chúng không phải là thu nhập phát sinh tại Việt Nam. Như vậy, số thuế thực tế phải trả tại Việt Nam có liên quan đến công việc làm của cá nhân NLĐNN trong ví dụ này là thấp so với thực tế nếu họ kê khai toàn bộ là tiền lương, tiền công thực chất họ được nhận cho công việc tại Việt Nam. Trong khi đó, người lao động Việt Nam không thể vận dụng “chiêu thức” này để thành lập công ty BVI vì bị vướng về quy định đầu tư ra nước ngoài của Việt Nam.

Tóm lại, từ những phân tích ở trên có thể thấy rằng nếu chi phí tiền lương, tiền công không quá chênh lệch giữa người lao động Việt Nam và NLĐNN thì chi phí thuế TNCN, bảo hiểm bắt buộc của Việt Nam sẽ là một trong những động lực thúc đẩy các đơn vị sử dụng lao động có khuynh hướng thích thuê mướn NLĐNN hơn người lao động Việt Nam. Khuynh hướng này sẽ có thể tăng cao trong bối cảnh thu nhập bình quân đầu người hàng năm của Việt Nam ngày càng gia tăng trong thời gian tới làm cho mức chênh lệch thu nhập bình quân đầu người giữa Việt Nam và các nước trong khu vực càng được thu hẹp.

Một trong những giải pháp cho vấn đề này trong thời gian tới là nên xem xét bãi bỏ một số khoản thu nhập từ tiền lương, tiền công của NLĐNN mà theo quy định hiện hành sẽ không phải tính vào thu nhập chịu thuế. Bên cạnh đó, cần xem xét giảm các mức thuế TNCN hiện hành để không tạo sự khác biệt quá lớn giữa việc trả thuế tại Việt Nam hay trả thuế tại nước ngoài. Các cơ quan thuế địa phương cũng cần yêu cầu NLĐNN nộp tờ khai thuế TNCN hàng năm của họ ở nước mà họ là công dân hay là cá nhân cư trú để đối chiếu xem có khoản thu nhập chịu thuế nào mà phải chịu thuế tại Việt Nam nhưng họ chỉ kê khai nộp thuế ở nước ngoài để có cơ sở truy thu thuế. Thêm vào đó, cần kiểm tra chặt chẽ các loại dịch vụ được các công ty từ các thiên đường thuế cung cấp cho các doanh nghiệp tại Việt Nam để xem các giao dịch thực tế có phát sinh không. Hy vọng, với những biện pháp này, sẽ giúp giảm thiểu đáng kế việc tuyển dụng NLĐNN làm việc tại các doanh nghiệp tại Việt Nam.

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Luật sư Nguyễn Hữu Phước – Công ty luật Phước & Các Đồng Sự

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[1] Khoản 1, Điều 1, Thông tư 62/2009/TT-BTC của Bộ Tài Chính.ngày 27/3/2009.

[2] Điểm a, Khoản 2, Điều 1 Thông tư 62/2009/TT-BTC của Bộ Tài Chính ngày 27/3/2009.

[3] Khoản 1 và Khoản 2, Mục I, Chương A, Thông tư 84/2008/TT-BTC của Bộ Tài Chính ngày 30/9/2008.

[4] Điều 91 và 92 của Luật Bảo hiểm xã hội

[5] Điều 102 Luật Bảo hiểm xã hội

[6] Hướng dẫn số 862/ HD-TLĐ của Tổng liên đoàn lao động Việt Nam ngày 1/6/2009

1077 Bình luận

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