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An overview by DFDL, Taxand Vietnam
Vietnam has recently introduced a new decree to update Vietnam’s Corporate Income Tax rules for capital gains from share or capital transfers by foreign investors. The previous 20% CIT on net gains is replaced by a 2% deemed tax on gross proceeds from transfers of capital in limited liability companies or shares in non-public joint-stock companies.
The rules apply to both direct and indirect transfers involving offshore entities holding Vietnamese subsidiaries. Certain internal group restructurings are exempt, provided they do not change the ultimate parent company or generate income. The decree does not yet include the tax declaration form for the new 2% rate; further guidance, including the filing template, is expected from the Ministry of Finance.
Jack Sheehan and Lan Hua from our Vietnamese member firm DFDL have published a more detailed overview of the decree here.
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Corporate Profit Tax | Cross border | Income Tax | International Tax | Tax | Vietnam | Withholding Tax