Certain specific cases determined as constituting a “Permanent Establishment in Vietnam”
(i) Equipment, machineries, self-unloading vessels that foreign companies set up in the sea area of Vietnam;
(ii) Ships, rigs employed for the service provision of foreign companies in Vietnam;
(iii) Using warehouse of buyers in Vietnam;
(iv) On-the-spot import and export transactions;
(v) Goods trading via bonded warehouses;
(vi) Sales of goods/services via sole agents.
In light of the above strict views of the tax authorities on PE determination, we note that the assessment of the transactions in practice would be more complicated. We therefore recommended that in case of having similar transactions, the company should carefully analyse the relevant criteria to determine whether or not the foreign parties constitute a PE in Vietnam for DTA application. If the company would like to discuss further on a specific case, please kindly contact us for further practical discussion.
Certain specific cases determined as constituting a “Permanent Establishment in Vietnam”(i) Equipment, machineries, self-unloading vessels that foreign companies set up in the sea area of Vietnam;(ii) Ships, rigs employed for the service provision of foreign companies in Vietnam;(iii) Using warehouse of buyers in Vietnam;(iv) On-the-spot import and export transactions;(v) Goods trading via bonded warehouses;(vi) Sales of goods/services via sole agents.In light of the above strict views of the tax authorities on PE determination, we note that the assessment of the transactions in practice would be more complicated. We therefore recommended that in case of having similar transactions, the company should carefully analyse the relevant criteria to determine whether or not the foreign parties constitute a PE in Vietnam for DTA application. If the company would like to discuss further on a specific case, please kindly contact us for further practical discussion.
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