Comprehensive avoidance of double taxation agreement
between Hong Kong and Vietnam finally come into effect
2009-8-26 The comprehensive avoidance of double taxation agreement between Hong Kong and Vietnam ("HK/Vietnam DTA") became effective on August 12th, 2009. The HK/Vietnam DTA will be effective in Hong Kong for any year of assessment beginning on or after April 1st, 2010 and in Vietnam from January st, 2010.
This is the fifth comprehensive DTA that Hong Kong entered into with other jurisdictions so far - the others being the Mainland China, Belgium, Thailand and Luxemburg.
Under this agreement, Hong Kong employees will be exempt from Vietnamese personal income tax (and vice versa) provided that: (1) they do not spend more than 183 days in Vietnam in any 12-month period commencing or ending in the tax year concerned; (2) their compensations are not paid by, or on behalf of, an employer who is a resident of Vietnam; and (3) the remuneration is not borne by a permanent establishment in Vietnam.
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