The tax treaty between New Zealand and Vietnam entered into force on may 5th, 2014. The treaty, signed August 5th, 2013, applies to income tax of both countries and includes the following withholding rates:
The treaty varies from the current OECD model with regards to service permanent establishments (PE), and PEs for activities related to the exploration or exploitation of nature resources, or the operation of substantial equipment.
A service PE will be deemed constituted when an enterprises from one country furnishes service in the other country through employees or other engaged personnel for the same or connected project when such activities continue for an aggregate period of 6 months or more in a 12 month period.
In the case of activities related to exploration or exploitation of nature resources, or the operation of substantial equipment, no time period is given.
Under the treaty, both countries provide for the credit method to eliminate double taxation.
The treaty will become effective in regards to withholding tax on or after January 1st, 2015, for both countries. For other tax matters, the treaty will be effective for Vietnam in relation to income, profits or gains arising on or after that date, and for New Zealand in relation to tax periods beginning on or after that date.
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