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Uni 09-08-2018 - Guidance on double taxation avoidance agreement for loan interest

Issue date: 9/8/2018 | 10:47:49 AM
OFFICIAL LETTER 53154/CT-TTHT DATED 31 JULY 2018 OF HA NOI TAX DEPARTMENT APPLYING TO DOUBLE TAXATION AVOIDANCE AGREEMENT FOR LOAN INTEREST

Official letter 53154/CT-TTHT dated 31/07/2018 of Ha Noi Tax Department guiding on double taxation avoidance agreement for loan interest:

Loan interest incurred in Viet Nam on or after 26/11/2015, due to the Company to any Japanese resident related to the debt guaranteed by the Japan Insurance and Ex- change Insurance Agency (NEXI), insurance or indirect funding, shall be exempt from taxation. Vietnam pursuant to paragraphs 3 and 4 of Article 11 of the Agreement between the Government of Viet Nam and the Government of Japan on the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Income Taxes. The company must make a dossier of tax exemption and reduction under the Agreement to the tax authority under the guidance in Item b.2, Clause 3, Article 22 of Circular No. 156/2013 / TT-BTC.

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