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Uni 17-09-2018 - Guidance on agreements on avoidance of double taxation for income of capital transfer

Issue date: 17/9/2018 | 8:53:34 AM
OFFICIAL LETTER 5241/CT-TTHT DATED 31 AUG 2018 OF HUNG YEN TAX DEPARTMENT GUIDING ON AGREEMENT ON AVOIDANCE OF DOUBLE TAXATION FOR INCOME OF CAPITAL TRANSFER

Official letter 5241/CT-TTHT dated 31/08/2018 of Hung Yen Tax Department guiding on Vietnam-Korea tax agreement on capital transfer is as follows:

In cases where Korean investors transfer their contributed capital at a company headquartered in Vietnam, if at the time of capital transfer or in the next fiscal year, the company headquartered in Vietnam shall have a price ratio Real estate accounts for more than 50% of assets, income from transfer of contributed capital is subject to CIT in Vietnam. Where the value of real estate is equal to or less than 50% of the value of assets, income from capital contribution shall not be subject to CIT in Vietnam.

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