Official letter 39642/CTHN-TTHT about CIT of capital transfer:
In case, foreign organizations generate income originating in Vietnam from capital transfer, they are subject to CIT in Vietnam. In case the capital transferee is also a foreign organization that does not operate under the Investment Law or the Enterprise Law, the enterprise established under the law of Vietnam where the foreign organization invests its capital is responsible for declaring and paying change the amount of CIT payable from capital transfer activities of foreign organizations.
