The Cyprus-Vietnam DTT, aligns with international tax standards, including the Organisation for Economic Co-operation and Development (OECD) and United Nations Model Conventions (UN Model).

We provide below key articles included in the Cyprus-Vietnam DTT:

Key provisions

1. Permanent establishment (PE)

Key provisions on PE include:

• Construction projects lasting at least 6 months.
• Furnishing of services for at least 6 months within a 12-month period.
• Exploration/exploitation of natural resources (no time threshold).

2. Dividends, interest, royalties

Key provisions on dividends, interest and royalties include:

• Dividends -
• • Maximum 5 per cent tax if the beneficial owner (BO) is a company holding at least 70 per cent of the paying company’s capital or has invested at least USD 10 million.
  • Otherwise, capped at 10 per cent tax.
• Interest - maximum 10 per cent tax on the gross amount of interest.
• Royalties - maximum 10 per cent tax on gross amount of royalties.

3. Capital gains tax (CGT)

Key provisions on CGT include:

• The country of origin retains the right to tax gains from shares in property-rich companies.
• Gains from shares representing over 15 per cent of a company’s capital may also be taxed by the country of origin.

4. Methods of eliminating double taxation

• The Cyprus-Vietnam DTT sets out specific provisions regarding the methods applied by each contracting state to eliminate double taxation.

Benefits for businesses and investors

The Cyprus-Vietnam DTT provides clarity and stability in the tax treatment of transactions between the two countries, ensuring fair treatment while preventing tax evasion and double taxation. By safeguarding transparent tax practices, the Cyprus-Vietnam DTT enhances investor confidence and supports the development of stronger trade and economic ties between Cyprus and Vietnam.

The official press release regarding the Cyprus – Vietnam DTT can be found here

The Cyprus-Vietnam DTT (available in Greek, Vietnamese and English) can be found here