OFFICIAL LETTER 1559/CT-TTHT DATED 30 JULY 2015 OF BAC NINH TAXATION DEPARTMENT IN GUIDANCE OF DETERMINING PERMANENT RESIDENT ESTABLISHMENT
According to official letter 1559/CT-TTHT:
In case, Cresyn Co.,Ltd is the resident permanent establishment in Korea, signs contracts with Cresyn Ha Noi, and authorizes Cresyn Ha Noi to deliver/receive with enterprises in Viet Nam under on-site export & import form, Cresyn Co.,Ltd is considered resident establishment in Viet Nam, is not exempted from FCT under double avoidance agreement between Viet Nam and Korea. The income received from Cresyn Co.,Ltd for providing goods to Samsung Viet Nam must be imposed on FCT.
