Applying Double Tax Avoidance Agreements (“DTA”) is a measure which helps companies to reduce the tax expenses in transactions with parties being residents of a country who entered into a DTA with Vietnam. However, understanding and correctly applying the DTA is the prerequisite condition to help the tax payers mitigate the risk of being subject to tax clawback by the tax authorities. One of the difficulties in applying for tax relief and exemption under the DTA is to determine whether the foreign parties have a Permanent Establishment (“PE”) during the transaction or not. Upon the assessment of the DTA notification dossier, the tax authorities now tend to have stricter views on the PE. In this Alert, we would like to analyze the tax authorities’ view on the PE, especially