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Iran-Vietnam

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Tax Treaty between Iran and Vietnam has Entered into Force

According to a recent update from the Vietnamese government, the income tax treaty with Iran entered into force on 26 June 2015. The treaty, signed 14 October 2014, is the first of its kind between the two countries.

Taxes Covered

The treaty covers Iranian income taxes on real estate, agriculture, salary, occupation (business), and legal persons. It covers Vietnamese personal income tax and business income tax.

Service PE

The treaty includes the provision that a permanent establishment will be deemed constituted when an enterprise furnishes services in a Contracting State through employees or other engaged personnel for the same or connected project for a period or periods aggregating more than 6 months within any 12-month period.

Withholding Tax Rates

  • Dividends - 10%
  • Interest - 10%
  • Royalties - 10%
  • Fees for Technical Services (technical, managerial or consultancy) - 8%

Capital Gains

The following capital gains derived by a resident of one Contracting State may be taxed by the other State:

  • Gains from the alienation of immovable property situated in the other State;
  • Gains from the alienation of movable property forming part of the business property of a permanent establishment in the other State;
  • Gains from the alienation of shares or other corporate rights in company, the assets of which directly or indirectly consist mainly of immovable property situated in the other State; and
  • Gains from the alienation of shares, other than those mentioned above, in a company resident in the other State

Gains from the alienation of other property by a resident of a Contracting State may only be taxed by that State.

Double Taxation Relief

Both countries apply the credit method for the elimination of double taxation.

Effective Date

The treaty applies in Iran from 21 March 2016 (first day of Farvardin - Iranian calendar), and in Vietnam from 1 January 2016.

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