A recent ruling from the Vietnam GDT has deemed that the Vietnam subsidiary of a multinational company is actually a PE of the foreign parent. As a result, the revenue share that the subsidiary pays to the foreign parent cannot be exempt from Vietnam withholding tax under the DTA Vietnam has with the country of […]

On 16 December 2008, the Government of the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”), and the Government of the Socialist Republic of Vietnam (“Vietnam”) have signed their first double taxation agreement (hereafter “HK-VN DTA”)[1]. The HK-VN DTA is bound to generate much interest from practitioners and from the […]

With the issuance of Circular 60/2012/TT-BTC dated 12 April 2012 (Circular 60) on Foreign Contractor Tax (FCT), income received by a foreign contractor with respect to online advertising and online training is now subject to withholding tax in Vietnam. Under the prior Circular 134/2008/TT-BTC dated 31 December 2008 (Circular 134), income from advertising and training […]