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On 12 September 2012, Vietnam and Singapore signed a second protocol to amend their tax treaty, most significantly with respect to services permanent establishments (PE) and gains on shares of companies holding immovable property. We highlight the following notable points: Capital gains on shares of companies that hold property With respect to the capital gains […]

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 […]