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Corporate Taxation

Ho Chi Minh City GMT +7

EY +84 (28) 3824-5252

20th Floor Fax: +84 (28) 3824-5250

Bitexco Financial Tower 2 Hai Trieu Street District 1

Ho Chi Minh City Vietnam

Principal Tax Contact

Robert King +84 (28) 3824-5252

Mobile: +84 902-468-806

Email: robert.m.king@vn.ey.com

Financial Services

Thinh Xuan Than +84 (28) 3824-5252

Mobile: +84 976-989-666

Email: thinh.xuan.than@vn.ey.com

International Tax Services – Transfer Pricing

Phat Tan Nguyen +84 (28) 3824-5252

Mobile: +84 938-364-777

Email: phat.tan.nguyen@vn.ey.com

International Tax Services – Global Tax Desk Network

Cheon Ju Lee, +84 (28) 3824-5252

Korea (South) Mobile: +84 909-998-415 Email: cheon.ju.lee@vn.ey.com

Takahisa Onose, +84 (28) 3824-5252

Japan Mobile: +84 972-063-888

Email: takahisa.onose@vn.ey.com

Business Tax Services

Thinh Xuan Than +84 (28) 3824-5252

Mobile: +84 976-989-666

Email: thinh.xuan.than@vn.ey.com

Business Tax Advisory

Thinh Xuan Than +84 (28) 3824-5252

Mobile: +84 976-989-666

Email: thinh.xuan.than@vn.ey.com

Transaction Tax

Thy Thi Anh Huynh +84 (28) 3824-5252

Mobile: +84 903-028-993

Email: thy.anh.huynh@vn.ey.com

People Advisory Services

Anh Thi-Kim Ngo +84 (28) 3824-5252

Mobile: +84 909-779-254

Email: anh.kim.ngo@vn.ey.com

Indirect Tax

Thinh Xuan Than +84 (28) 3824-5252

Mobile: +84 976-989-666

Email: thinh.xuan.than@vn.ey.com

Legal Services

Thinh Xuan Than +84 (28) 3824-5252

Mobile: +84 976-989-666

Email: thinh.xuan.than@vn.ey.com

Hanoi GMT +7

EY +84 (24) 3831-5100

8th Floor, CornerStone Building Fax: +84 (24) 3831-5090 16 Phan Chu Trinh Street

Hoan Kiem District Hanoi

Vietnam

Principal Tax Contact

Huong Vu +84 (24) 3831-5100

Mobile: +84 903-432-791

Email: huong.vu@vn.ey.com

International Tax Services – Global Tax Desk Network

Junichi Harada, +84 (24) 3831-5100

Japan Mobile: +84 978-959-666

Email: junichi.harada@vn.ey.com

Kyung Hoon Han, +84 (24) 3831-5100

Korea (South) Mobile: +84 932-296-865

Email: kyung.hoon.han@vn.ey.com

Business Tax Services

Huong Vu +84 (24) 3831-5100

Mobile: +84 903-432-791

Email: huong.vu@vn.ey.com

Business Tax Advisory

Huong Vu +84 (24) 3831-5100

Mobile: +84 903-432-791

Email: huong.vu@vn.ey.com

Trang Pham +84 (24) 3831-5100

Mobile: +84 915-022-804

Email: trang.pham@vn.ey.com

Transaction Tax

Huong Vu +84 (24) 3831-5100

Mobile: +84 903-432-791

Email: huong.vu@vn.ey.com

People Advisory Services

Huyen Thi Thanh Nguyen +84 (24) 3831-5100

Mobile: +84 912-124-562

Email: huyen.thi.nguyen@vn.ey.com

Indirect Tax

Trang Pham +84 (24) 3831-5100

Mobile: +84 915-022-804

Email: trang.pham@vn.ey.com

Because of the rapidly changing economic situation in Vietnam, readers should obtain updated information before engaging in transactions.

A. At a glance

Corporate Income Tax Rate (%) 20 (a)

Capital Gains Tax Rate (%) 20 (b)

Branch Tax Rate (%) 20

Withholding Tax (%)

Dividends 0

Interest 5

Royalties 10

Branch Remittance Tax 0

Net Operating Losses (Years)

Carryback 0

Carryforward 5 (c)

(a) The standard corporate income tax rate is 20%. However, tax incentives are available (see Section B). Enterprises operating in the oil and gas industry are subject to corporate income tax rates ranging from 32% to 50%, depending on the location and specific project conditions. Enterprises engaging in pros- pecting, exploration and exploitation of mineral resources (for example, sil- ver, gold and gemstones) are subject to corporate income tax rates of 40% to 50%, depending on the project’s location.

(b) Gains derived from sales of capital or shares in entities are subject to tax at a rate of 20%. Transfers of securities by foreign investors are subject to pre- sumptive tax of 0.1% on total sales proceeds, regardless of whether the transfer is profitable.

(c) See Section C.

B. Taxes on corporate income and gains

Corporate income tax. The following types of enterprises are sub- ject to corporate income tax:

• Enterprises established under the Law on Enterprises, the Law on Investment, the Law on Credit Organizations, the Law on Insurance Business, the Law on Securities, the Law on Oil and Gas, the Trade Law and other legal entities including joint stock companies, limited liability companies, partnerships, private businesses, law offices, private public notary offices, parties to business cooperation contracts, parties to oil and gas product sharing contracts, and joint operation companies

• Public and non-public organizations engaged in business

• Organizations established under the Law on Cooperatives

• Businesses established under foreign laws that have a perma- nent establishment in Vietnam

• Other organizations conducting production and business activ- ities that generate taxable income

Rates of corporate income tax. The standard corporate income tax rate is 20%. However, tax incentives are available (see Tax incen­ tives).

The rate of corporate income tax applicable to activities of explo- ration and exploitation of oil, gas and other precious natural re- sources ranges from 32% to 50%, depending on the project.

Tax incentives

Incentive tax rates. Preferential tax rates of 10%, 15% or 17% may be available to eligible projects in industries or locations that are encouraged by the government.

A 10% rate for the 15-year period beginning with the first year of revenue may be available for the following:

• Income from new investment projects in areas with especially difficult socioeconomic conditions, and in economic zones and high-technology zones

• Income from new investment projects that are engaged in the following:

— Scientific research and technological development

— Application of high technologies in the list of prioritized high technologies provided by the Law on High Technology

— Cultivation of high technologies

— Cultivation of high-technology enterprises

— High-risk investment in the development of high technolo- gies in the list of prioritized high technologies provided by the Law on High Technology

— Construction investment and commercial operation of establishments nursing high technologies

— Investment in development water plants, power plants, water supply and drainage systems, bridges, roads, railways, air- ports, seaports, river ports airfields, stations and other par- ticularly important infrastructure facilities determined by the prime minister

— Software production

— Production of composite materials, light building materials, rare materials, renewable energy, clean energy and energy from waste destruction

— Development of biological technology

• Income of new investment projects in the field of environmen- tal protection, including manufacturing of equipment for treat- ing environmental pollution and equipment for environmental observation and analysis, environmental pollution treatment and protection, collection and treatment of wastewater, exhaust and solid wastes, and recycling and reuse of wastes

• Income of high-technology enterprises and agricultural enter- prises that apply high technologies according to the Law on High Technology

• Income from new investment projects that make products sup- portive of the high-technology industry in line with the Law on High Technology or products supportive of certain industries, including textile and garment, footwear, electronics, informa- tion technology, automobile assembly and mechanics, and that are not domestically produced as of 1 January 2015 or meet the quality standard of the European Union or an equivalent standard

• Income from new investment projects in the production sector (except for projects producing goods subject to special sales tax and mineral exploitation projects) that have investment capital of at least VND6 trillion, if the capital is disbursed within three years from the date of the investment certificate and if either of the following conditions is satisfied:

— The project’s total revenue reaches VND10 trillion per year within three years from the first year of revenue.

— The project employs more than 3,000 employees.

• Large-scale manufacturing projects (excluding projects man- ufacturing products subject to special sales tax or exploiting mineral resources) if all of the following conditions are satisfied:

— The investment capital must be at least VND12 trillion.

— The technology used must be certified in accordance with the Law on High Technology and the Law on Science and Technology.

— The capital disbursement must be made within five years of the licensing date.

A 10% or 15% rate applies for the entire period of operation for enterprises in the sectors of education and training, occupational training, health care, culture, sports, environment, social housing, forestry, agriculture, aquaculture, salt production and publishing. However, this incentive is subject to detailed conditions provided separately by the prime minister.

A 17% rate for the 10-year period beginning with the first year of revenue may apply to the following:

• Income from new investment projects based in areas with dif- ficult socioeconomic conditions

• Income from new investment projects that are engaged in the production of high-qualified steel or energy-saving products, the manufacturing of machinery and equipment serving agri- culture, forestry, aquaculture, salt production, production of irrigation equipment, the production of foodstuff for cattle and the development of traditional trades

The duration of the application of preferential tax rates described above is counted consecutively from the first year in which enter- prises generate turnover from new investment projects eligible for tax incentives. For high-technology enterprises and agricultural enterprises applying high technologies, this duration is counted from the year in which they are certified as high-technology enterprises or agricultural enterprises applying high technologies. For other projects applying high technologies, this duration is counted from the year in which they are granted certificates of projects applying high technologies.

If, within an assessment period, an enterprise has both incentiv- ized activities and normal activities, it must conduct a separate accounting for income from each activity to declare and pay tax separately. Otherwise, taxable income must be prorated according to the ratio of revenue or deductible expenses of each activity to the total revenue or deductible expenses.

Income and losses from incentivized activities and normal ac- tivities (except for transfers of mineral exploratory, mining and processing rights) may be netted against each other before the tax rate of the activity with the highest amount of income is applied.

Tax incentives previously granted as a result of the export ratio are repealed, effective from 1 January 2012. Affected taxpayers can adopt either tax incentives for the remaining incentive period based on the prevailing regulations effective at the time they were licensed or those effective from 31 December 2011. Taxpayers are required to notify the tax authorities regarding the tax incen- tive option selected.

Tax exemptions and tax reductions. Criteria for eligibility to tax holidays and reductions, which are set out in the corporate in- come tax regulations, are described below.

Four years of tax exemption and nine subsequent years of 50% reduction apply to the following:

• Income from new investment projects entitled to the 10% cor- porate income tax

• Income from new investment projects operating in the social- ized sectors and difficult socio-economic areas

Four years of tax exemption and 50% tax reduction for five sub- sequent years apply to income from new investment projects in the socialized sectors and in regions not included in the list of difficult socio-economic areas.

Two years of tax exemption and four subsequent years of 50% reduction apply to the following:

• Income from new investment projects in regions with difficult socio-economic conditions

• Income from new investment projects, including production of high-grade steel, production of energy-saving products, pro- duction of machinery or equipment used to serve agricultural, forestry, fishery or salt production, production of irrigation equipment, production and refinement of foodstuffs for cattle, poultry or aquatic products, and development of traditional trades

• Income from new investment projects in industrial zones (ex- cept for industrial zones located in regions with favorable socio- economic conditions)

The continuous period of tax exemption and reduction begins from the first year in which the enterprise earns taxable income from the new investment project that is granted tax incentives. If the enterprise does not have taxable income in the first three years, the period of tax exemption and reduction begins in the fourth year following the first year in which revenue is generated by the new project.

Capital gains. Gains derived from sales of shares or assignments of capital in enterprises are subject to tax at a rate of 20%. The taxable income equals the transfer price less the sum of the pur- chase price of the transferred capital and expenses incurred with respect to the transfer.

Foreign investors transferring “securities” (this is a specified term, which includes shares of public companies) are subject to presumptive tax at a rate of 0.1% on total sale proceeds, regard- less of whether the transfer is profitable.

Administration. Enterprises normally use the calendar year as their tax year. Enterprises that have their own particular charac- teristics of operational organization may choose a financial year of 12 months according to the Gregorian calendar and they must notify the local authorities of such year.

Enterprises must pay their quarterly income tax due within 30 days after the last day of the quarter. Enterprises must file a final income tax return and pay any balance of income tax due within 90 days after the end of the tax year. If the provisional quarterly payments are less than the final income liability for the year, the shortfall in excess of 20% of the final income tax liabil- ity is subject to late payment interest at a fixed rate of 0.03% per day.

An under declaration is subject to only a late-payment fine if it is self-corrected by the taxpayer. Otherwise, a penalty of 20% of the under declared tax is imposed. Late payments of tax are subject to interest at a rate of 0.03% of the unpaid amount per day.

Tax audits are performed on an ad hoc or selected basis. Any tax under declaration identified by the tax auditor is penalized at 20% (or 100% to 300% if considered to be tax evasion) and sub- ject to a prevailing interest rate of the tax liability for each day late, calculated from the statutory deadline to the date of actual payment.

Dividends. Dividends and branch remittances are not subject to withholding tax.

Withholding taxes on interest and royalties. The rate of withhold- ing tax on interest paid under loan contracts is 5%.

A withholding tax at a rate of 10% is imposed on royalties paid to foreign legal entities with respect to technology transfers and licensing.

Foreign tax relief. Vietnam has signed tax treaties with several countries that provide relief from double taxation (see Section F).

C. Determination of taxable income

General. The taxable income of an enterprise is the income shown in the financial statements, subject to certain adjustments. Tax- able income includes income derived from business operations and other activities.

An enterprise may deduct expenses if the following conditions are satisfied:

• The expenses are actually incurred and related to the produc- tion and business activities of the enterprise.

• The expenses are accompanied by complete invoices and source vouchers as required by law.

• Expenses of VND20 million or more must be supported with cashless payments (for example, bank transfers and payments with cards).

• The expenses are not on the list of nondeductible expenses shown below.

Certain expenses are not deductible in determining taxable in- come, including the following:

• Provisions that do not conform to the regulations of the Ministry of Finance (MOF)

• Accrued expenses not corresponding to taxable turnover that has been recognized

• Bonuses and life insurance expenses for employees that are not clearly stated in the labor contracts, the collective labor contracts, the financial regulations of the company or the re- ward regulations promulgated by the chairman of the board of management

• Interest payments on loans corresponding to equity that is not contributed

• Interest payments on loans borrowed from lenders that are not credit institutions or economic organizations that exceed 150% of the basic interest rate quoted by the State Bank of Vietnam at the time of the loan agreement

• Under recently enacted transfer-pricing regulations, loan inter- est expenses in excess of 20% of the total net profit generated from business activities plus loan interest expenses and amorti- zation costs arising in the period

• Expenses sourced from other funding and expenses paid from the Science and Technology Development Fund of the enterprise

• The portion of business management expenses allocated by a foreign company to its resident establishment in Vietnam (for example, head office charges allocated to the Vietnam branch) that exceeds the level allowed under the regulations

• Depreciation of fixed assets that are not used for business activities and/or supported by ownership documents

• Employees’ fringe benefits that exceed the cap of an average one month’s salary cost (calculated by dividing the yearly wage fund by 12) in the tax year

• Payments above VND1 million per person per month for con- tributions to a voluntary pension fund or purchase of voluntary pension insurance for employees

• Donations except for certain donations for education, health care, natural disasters or building charitable homes for the poor

• Management expenses allocated to permanent establishments in Vietnam by the foreign company that are not in accordance with the regulations

• Administrative penalties

• Input value-added tax (VAT) that has been credited or refunded, input VAT on the value of a car of nine seats or less that exceeds VND1,600,000,000, corporate income tax (except for the cor- porate income tax that a Vietnamese company pays on behalf of a foreign contractor under a net contract) and personal income tax (unless the employer pays net salary to employees)

• Expenses that do not correspond to taxable revenue

• Exchange-rate loss as a result of the revaluation of the year-end balance of money items in foreign currencies, except for the revaluation of payables in foreign currencies

• Exchange-rate loss arising in the process of capital construction of fixed assets, which is governed by a separate regulation of the MOF

Inventories. Inventory valuation should be consistent with the accounting principles and standards selected by the company and approved by the MOF. No specific guidelines have been estab- lished by the tax authorities.

Tax depreciation. Depreciation of fixed assets is normally comput- ed using the straight-line method. The MOF has issued guidelines setting forth the minimum and maximum years for depreciation of various assets, but companies may apply to the MOF for per- mission to use different time periods. The following are the mini- mum and maximum years of depreciation for certain categories of assets.

Asset

Years

Intangible assets

Up to 20

Buildings and factories

5 to 50

Tools and machinery

3 to 20

Transportation vehicles

6 to 30

Other fixed assets

2 to 40

Depreciation at rates exceeding those allowed by the MOF is not deductible for tax purposes. For cars with nine seats or less pur- chased by enterprises for business other than passenger transpor- tation, hotel or tourism, the depreciable amount is capped at VND1,600,000,000.

Relief for losses. Enterprises that incur losses may carry forward the losses to the following five years and claim such losses as deductions from taxable income. Losses must be wholly carried forward to consecutive years (including the year of a tax holiday).

Enterprises that incur losses from real-property transfers may carry forward the losses to offset income from all of their activities.

Carrybacks of losses are not allowed.

Groups of companies. Dependent production establishments of a company operating in different areas of Vietnam must declare and pay tax with the local tax authorities where the dependent estab- lishments’ offices are located based on the ratio of the expenses of the dependent establishment to the total expenses of the com- pany. The offsetting of losses and profits between parents and subsidiaries is not allowed.

D. Other significant taxes

The following table summarizes other significant taxes.

Nature of tax Rate

Value-added tax (VAT); imposed on all goods and services consumed in and imported into Vietnam, including goods and services subject to special consumption tax, except for non-taxable items

General rate 10%

Exports of goods and services 0%

Certain goods and services, such as water supply, agricultural goods, medical goods

and teaching aids 5%

Special consumption tax; imposed on imported or domestically produced cigarettes, beer, spirits, motor vehicles, fuel and air conditioners, and various services including casinos, betting, golf

courses and various places of entertainment 5% to 150%

Social insurance, health insurance and unemployment insurance contributions, on salaries (generally applicable to Vietnamese employees only); paid by

Employer

Social insurance; the contribution is based on the salary and other allowances of the employees as provided in the labor contract but not exceeding 20 times the minimum

salary 17.5%

(The rate of 17.5% consists of a 3% contribution to the maternity and illness fund, a 0.5% contribution to the labor and professional accident fund and a 14% contribution to the pension and death fund)

Health insurance; calculated on the same

base as social insurance 3%

Unemployment insurance 1%

Employee

Social insurance 8%

Health insurance 1.5%

Unemployment insurance 1%

Foreign contractor tax; rate depends on type

of business activity 0.1% to 10%

Land rent (land-use tax); imposed annually for the use of land; tax base is calculated by multiplying the amount of square meters of the land by land price rates, which vary by location; the higher land price rates apply to

Nature of tax Rate

land in Hanoi, Ho Chi Minh City and other

urban locations Various

Non-agricultural land use tax; taxable objects include residential land in all areas and land used for business purposes, except for certain cases

Residential land 0.03% to 0.15%

Non-agricultural land used for business

purposes 0.03%

Land not used in accordance with granted

purposes 0.15%

Environmental Tax; taxable objects consist of petroleum, oil, lubricants, black coal, hydrochlorofluorocarbon (HCFC) solutions, taxable plastic bags, herbicide termite insecticides, forest products protective agents and warehouse insecticides; rates from 1 January 2019

Petroleum, oil and lubricants VND1,000 to VND4,000

per liter/kilogram

Black coal VND15,000 to

VND30,000 per ton

HCFC solution VND5,000 per kilogram

Taxable plastic bags VND50,000 per kilogram Herbicide (restricted use category) VND500 per kilogram Termite insecticide

(restricted use category) VND1,000 per kilogram Forest products protective agents

(restricted use category) VND1,000 per kilogram Warehouse insecticides

(restricted use category) VND1,000 per kilogram Natural Resources Tax (NRT); payable

by industries exploiting Vietnam’s natural resources; taxable objects include metallic minerals, nonmetallic minerals, products of natural forests, natural marine products, natural mineral water, other natural resources and petroleum; tax base for NRT calculation includes the output of royalty-liable natural resources, royalty-liable price of

a unit of natural resource and royalty rate

Metallic minerals 10% to 20%

Nonmetallic minerals 6% to 27%

Products of natural forests 5% to 35%

Natural marine products 2% to 10% Natural mineral water and natural water 1% to 10% Other natural resources 10% to 20% Crude oil

Encouraged investment projects 7% to 23%

Other projects 10% to 29%

Natural gas and coal gas

Encouraged investment projects 1% to 6%

Other projects 2% to 10%

E. Miscellaneous matters

Foreign-exchange controls. Enterprises with foreign-owned capi- tal must open accounts denominated in a foreign currency or the Vietnam dong (VND) at a bank located in Vietnam and approved by the State Bank of Vietnam (SBV). All foreign-exchange trans- actions, such as payments or overseas remittances, must be in accordance with policies set by the SBV.

Enterprises with foreign-owned capital and foreign parties may purchase foreign exchange from a commercial bank to meet the requirements of current transactions or other permitted transac- tions, subject to the bank having available foreign exchange.

The government may guarantee foreign currency to especially important investment projects or assure the availability of foreign currency to investors in infrastructure facilities and other impor- tant projects.

Transfer pricing. The Vietnamese transfer-pricing regulations apply the arm’s-length principle to determine transfer prices of business transactions undertaken between related parties and is broadly consistent with the arm’s-length concept as set out in the Organisation for Economic Co-operation and Development’s Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD Transfer Pricing Guidelines). The applicable transfer-pricing methods under the Vietnamese trans- fer-pricing regulations closely resemble the methods provided by the OECD Transfer Pricing Guidelines and include the following:

• Comparable uncontrolled price method

• Resale price method

• Cost-plus method

• Profit-split method

• Comparable profit method (referred to as the transactional net margin method in the OECD Transfer Pricing Guidelines)

The Vietnamese regulations contain detailed transfer-pricing documentation requirements. The documentation must be pre- pared before the submission of the annual income tax return to substantiate the arm’s-length prices and submitted to the tax au- thority within a prescribed time limit on receipt of written request in a tax audit.

Advance pricing agreement (APA) regulations are largely in line with the OECD Transfer Pricing Guidelines and APA regimes in other tax jurisdictions. An APA is a binding agreement between a taxpayer and the tax authority that determines in advance the basis for tax calculation, transfer-pricing methods and arm’s-length prices of the covered related-party transactions for a specific time period. The APA period is five years with a renewal period of up to five years.

F. Treaty withholding tax rates

The withholding rates under Vietnam’s double tax treaties are listed in the following table.

Dividends

%

Interest

%

Royalties

%

Australia

10/15

10

10

Austria

5/10/15 (a)

10

7.5/10

Dividends

%

Interest

%

Royalties

%

Azerbaijan

10

10

10

Bangladesh

15

15

15

Belarus

15

10

15

Belgium

5/10/15 (a)

10

5/10/15

Brunei Darussalam

10

10

10

Bulgaria

15

10

15

Canada

5/10/15 (a)

10

7.5/10

China (mainland)

10

10

10

Cuba

5/10/15 (a)

10

10

Czech Republic

10

10

10

Denmark

5/10/15 (a)

10

5/15

Finland

5/10/15 (a)

10

10

France

7/10/15 (a)

– (b)

10

Germany

5/10/15 (a)

10

7.5/10

Hong Kong SAR

10

10

7/10

Hungary

10

10

10

Iceland

10/15 (a)

10

10

India

10

10

10

Indonesia

15

15

15

Iran

10

10

10

Ireland

5/10

10

5/10/15

Israel

10

10

5/15

Italy

5/10/15 (a)

10

7.5/10

Japan

10

10

10

Kazakhstan

5/15

10

5/10/15

Korea (North)

10

10

10

Korea (South)

10

10

5/15

Kuwait

10/15

15

20

Laos

10

10

10

Latvia

5/10 (a)

10

7.5/10

Luxembourg

5/10/15 (a)

10

10

Malaysia

10

10

10

Malta

5/15

10

5/10/15

Mongolia

10

10

10

Morocco

10

10

10

Mozambique

10

10

10

Myanmar

10

10

10

Netherlands

5/10/15 (a)

10

5/10/15

New Zealand

5/15 (a)

10

10

Norway

5/10/15 (a)

10

10

Oman

5/10/15 (a)

10

10

Pakistan

15

15

15

Palestinian Authority

10

10

10

Panama

5/7/12.5

10

10

Philippines

10/15 (a)

15

15

Poland

10/15 (a)

10

10/15

Portugal

5/10/15

10

7.5/10

Qatar

5/12.5

10

5/10

Romania

15

10

15

Russian Federation

10/15 (a)

10

15

San Marino

10/15

10/15

10/15

Saudi Arabia

5/12.5

10

7.5/10

Serbia

10/15

10

10

Seychelles

10

10

10

Dividends

%

Interest

%

Royalties

%

Singapore

5/7/12.5 (a)

10

5/10

Slovak Republic

5/10

10

5/10/15

Spain

7/10/15 (a)

10

10

Sri Lanka

10

10

15

Sweden

5/10/15 (a)

10

5/15

Switzerland

7/10/15 (a)

10

10

Taiwan

15

10

15

Thailand

15

10/15

15

Tunisia

10

10

10

Turkey

5/10/15 (a)

10

10

Ukraine

10

10

10

United Arab Emirates

5/15

10

10

United Kingdom

7/10/15 (a)

10

10

Uruguay

10

10

10

Uzbekistan

15

10

15

Venezuela

5/10 (a)

10

10

Non-treaty jurisdictions

0

5

10

(a) The rates vary depending on the percentage of the payer’s capital that is owned by the recipient of the dividends.

(b) The treaty with France does not cover the taxation of interest.

Vietnam has signed double tax treaties with Algeria, Cambodia, Croatia, Egypt, Estonia, Macedonia, the Macau Special Administrative Region (SAR) and the United States, but these treaties have not yet been ratified or have not yet taken effect.