Từ Thiện Và Thuế

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Trong cuộc sống mưu sinh khó khăn vất vả hàng ngày, con người càng phải biết đùm bọc, thương yêu, chia sẻ lẫn nhau. Qua hai vụ “đng bào các tnh Bc Trung B b bão lt gây thit hi nng n” và vụ “Sp cu Cn Thơ” làm hàng chục người thiệt mạng trong  tháng 09/2007 vừa qua đã cho thấy tấm lòng đùm bọc, thương yêu, chia sẻ lẫn nhau của cá nhân (CN), doanh nghiệp (DN) trong cả nước.

Tuy nhiên, có rất nhiều DN hết sức băn khoăn là những khỏan chi phí mà họ dành cho công tác từ thiện có được xem là một khỏan chi phí hợp lý, hợp lệ được trừ cho mục đích tính thuế thu nhập DN hay không? Tương tự như vậy, các CN cũng quan tâm là số tiền,  hiện vật mà họ chi cho từ thiện có được xem là một khỏan được giảm trừ không? Cũng như vậy, về phía người nhận, dù chưa phải lo lắng lắm nhưng trong tương lai không xa họ cũng băn khoăn không kém vì không biết khỏan hiện kim, hiện vật mà họ nhận có phải là đối tượng chịu thuế thu nhập CN hay không? Nếu phải chịu thì áp dụng mức thuế suất nào, cách tính thuế ra sao?  nếu họ không tự nguyện kê khai thì sẽ chịu hậu quả pháp lý như thế nào?

Về quy định của Nhà nước liên quan đến vấn đề này, Nghị định 24/2007/ND-CP ngày 14/02/2007 của Chính phủ quy định chi tiết thi hành Luật Thuế Thu nhập DN quy định là chi từ thiện không được tính vào chi phí hợp lý, hợp lệ của DN vì Chính phủ cho rằng chi phí này không liên quan đến doanh thu và thu nhập chịu thuế của DN. Tuy nhiên, nhìn ở góc độ của DN, họ lại cho rằng chi phí này thực tế là có liên quan trực tiếp đến họat động kinh doanh của họ. Khi DN làm từ thiện, ngòai lý do lá lành đùm lá rách, thì qua công tác từ thiện, người tiêu dùng sẽ biết đến họ nhiều hơn; thương hiệu của họ sẽ được chú ý; hàng hóa, dịch vụ của họ sẽ gây được mối thiện cảm tốt với người tiêu dùng và vì thế doanh số bán hàng của họ sẽ tăng hơn trong tương lai. Đã có rất nhiều hội thảo bàn tròn bàn về cách tháo gỡ những vướng mắc về thuế do Bộ Tài chính, Tổng Cục thuế và các hiệp hội kinh doanh phối hợp tổ chức trong những năm gần đây và vấn đề chi phí cho từ thiện luôn được các DN quan tâm và đưa vào phần hỏi đáp. Tuy nhiên, đại diện của Bộ Tài chính và Tổng Cục thuế đều dừng lại ở mức độ ghi nhận và hứa sẽ kiến nghị lên các cấp có thẩm quyền cao hơn để có những điều chỉnh cho phù hợp với tình hình thực tế và thông lệ quốc tế nhưng mãi cho đến nay vẫn chưa có thay đổi gì cụ thể về vấn đề này. Tương tự, vế phía CN tham gia công tác từ thiện, theo quy định của Pháp lệnh về Thuế thu nhập cho những người có thu nhập cao hiện hành, các khỏan chi từ thiện cũng không được xem là một khỏan được giảm trừ khỏi thu nhập chịu thuế.

Hậu quả của vấn đề này là các DN và CN không được khuyến khích làm từ thiện trừ khi họ thật sự quá nhiệt tâm với công tác này mà không quan tâm đến việc khỏan chi từ thiện có được xem là chi phí hợp lý, hợp lệ hay là chi phí được giảm trừ hay không. Điều này đưa đến hậu quả tiếp theo là Nhà nước sẽ phải tiếp tục gánh vát các trách nhiệm xã hội mà đáng lẽ ra họ có thể san sẻ bớt một phần trách nhiệm cho các DN và những tầng lớp giàu có trong xã hội. Về phía người nhận (đa số là các CN, hộ gia đình), khỏan thu nhập từ từ thiện lại không phải là đối tượng chịu thuế thu nhập do Nhà nước không coi đây là một lọai thu nhập cao. Do đó, họ thỏai mái nhận các khỏan thu nhập từ từ thiện mà không cần quan tâm đến việc họ có phải nộp thuế hay không.

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Về vấn đề này, ở đa số các nước phát triển, các khỏan chi từ thiện của DN là một khỏan chi phí hợp lý, hợp lệ cho mục đích tính thuế thu nhập DN. Tương tự, các khỏan chi của CN cho từ thiện cũng được xem là một khỏan được giảm trừ vào thu nhập chịu thuế của họ. Dĩ nhiên, ở mỗi nước, mức được xem như chi phí hợp lý, hợp lệ của DN hay một khỏan giảm trừ cho CN sẽ khác nhau, tùy thuộc vào đặc thù của từng nước. Ở một số nước, họ cho trừ hòan tòan số tiền làm từ thiện vào thu nhập chịu thuế. Ở một số nước khác, họ cho trừ thậm chí còn hơn cả số tiền làm từ thiện nhằm mục đích khuyến khích mọi người làm từ thiện nhiều hơn, nhưng cũng có một số nước thì họ chỉ cho trừ một phần nào đó mà thôi hay cho trừ tòan bộ nhưng phải được sự chấp thuận trước của cơ quan thuế. Điều này, khuyến khích rất nhiều CN và DN làm từ thiện vì thay vì phải đóng thuế cho Nhà nước, họ làm từ thiện. Vừa có lợi ích cho cộng đồng, họ còn quảng bá được thương hiệu đồng thời lại được đưa vào chi phí hợp lệ của DN. Ở những nước này, các nhà làm luật quan niệm rằng Nhà nước có khuynh hướng sử dụng tiền không hiệu quả bằng CN, DN nên Nhà nước khuyến khích DN và CN dùng tiền của họ hỗ trợ một cách hiệu quả cho những người nghèo. Một ví dụ đơn cử là Quỹ Từ Thiện Bill & Melinda do Bill Gates và vợ thành lập năm 1997 và chính thức khai trương năm 2000 với một số tiền quỹ lên đến hơn 28 tỉ USD, trong đó phần lớn được vợ chồng Bill Gates đóng góp. Quỹ Từ Thiện Bill & Melinda tập trung vào các lĩnh vực giáo dục, y tế toàn cầu, cải thiện thư viện công cộng và hỗ trợ những gia đình gặp nạn. Nhiều người tò mò không hiểu sao vợ chồng Bill Gates lại bỏ ra một số tiền lớn như vậy để phục vụ cho mục đích từ thiện thay vì dùng nó để phát triển họat động kinh doanh sẳn có của Micro Soft trong khi Bill Gates là một nhà kinh doanh tầm cỡ, rất biết cách chi tiền như thế nào cho đúng và hợp lý. Dĩ nhiên, như đã nói ở trên, mặc dù mục đích đầu tiên của người làm từ thiện là chia sẻ, giúp đở người khác đang gặp khó khăn nhưng trong một chừng mực nào đó, họ cũng muốn được Nhà nước và xã hội ghi nhận những đóng góp của họ cho cộng đồng qua các hình thức khác nhau. Theo quy định của Luật thuế của Mỹ (tùy từng tiểu bang), khỏan tiền chi cho từ thiện này xem như là một khỏan giảm trừ vào thu nhập chịu thuế của người làm từ thiện (dĩ nhiên là theo một mức tối đa theo quy định theo luật thuế của Mỹ). Như vậy, người làm từ thiện cùng lúc đạt được cả ba thứ, đó là vừa làm cho người khác vượt qua khó khăn, giảm nhẹ gánh nặng trách nhiệm cho Nhà nước và cũng làm cho chính bản thân người làm từ thiện được hạnh phúc hơn.

Về những dự kiến thay đổi của Luật pháp Việt Nam về vấn đề này, theo bản Dự thảo Luật Thuế Thu nhập CN mới nhất sẽ được Quốc hội thông qua tại kỳ họp cuối năm 2007 và sẽ được chính thức áp dụng từ ngày 01/01/2009, thu nhập từ từ thiện của “CN có hòan cảnh khó khăn” sẽ là thu nhập không chịu thuế. Tuy nhiên, Dự thảo chưa đưa ra định nghĩa như thế nào thì một người được xem là “cá nhân có hòan cnh khó khăn” nên cũng không biết được là ai sẽ được miễn đóng thuế và ai phải đóng khi nhận từ thiện,? Bên cạnh đó, Ủy ban Thường vụ Quốc hội vừa đưa Dự thảo ra thảo luận, chỉnh lý nội dung. Ý kiến chung của Ủy ban Thường vụ Quốc hội là cho trừ vào thu nhập chịu thuế trước khi tính thuế của CN đối với các khỏan đóng góp cho từ thiện. Tuy nhiên, chỉ có các khỏan chi từ thiện cho trẻ em có hòan cảnh đặc biệt khó khăn, người tàn tật, người già không nơi nương tựa, các khỏan chi đóng góp vào các quỹ từ thiện, quỹ khuyến học là được trừ mà thôi. Dự thảo cũng nói là Chính phủ sẽ quy định cụ thể về việc giàm trừ đối với các khỏan đóng góp từ thiện. Do đó, chúng ta phải chờ đến nghị định của Chính phủ và Thông tư của Bộ Tài chính mới có thể biết rõ hơn về vấn đề này.

Theo ý kiến riêng của người viết, Nhà nước cần khuyến khích các DN, CN tham gia làm từ thiện qua việc cho các khỏan chi của DN Việt Nam cho mục đích từ thiện là một khỏan chi phí hợp lý, hợp lệ và được trừ khỏi thu nhập chịu thuế của DN. Tuy nhiên, để tránh trường hợp một số DN lạm dụng chi phí từ thiện để phục vụ cho những mục đích kinh doanh riêng khác của riêng họ mà làm mất đi hòan tòan ý nghĩa tốt đẹp của công tác từ thiện, mức đóng góp cho từ thiện được xem là chi phí hợp lý, hợp lệ sẽ theo một mức khống chế do Nhà nước quy định tại từng thời điểm cũng như chỉ có một số trường hợp mà thôi. Nếu DN muốn chi vượt số tiền này hay chi cho các trường hợp khác thì phải lấy thu nhập sau thuế của họ để chi. Mức khống chế này sẽ thay đổi hàng năm để phản ánh mức lạm phát, trượt giá. Đối với các khỏan chi cho từ thiện của CN, dù rằng theo nội dung của Dự thảo và ý kiến Ủy ban Thường vụ Quốc hội gần đây, thì các khỏan thu nhập từ từ thiện không phải là thu nhập chịu thuế thu nhập CN cũng như các khỏan chi cho từ thiện của CN sẽ được trừ khỏi thu nhập chịu thuế nhưng cần phải quy định chi tiết và rõ ràng trong nghị định của chính phủ và thông tư của Bộ Tài chính về các khái niệm này để mọi người dễ dàng trong áp dụng cũng như tránh trường hợp đối tượng nộp thuế lợi dụng họat động từ thiện cho các mục đích khác làm ảnh hưởng đến truyền thống tốt đẹp của Việt Nam và định hướng chủ trương của Chính phủ.

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 LS Nguyễn Hữu Phước Công ty Luật Phước & Các Đồng Sự

 

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