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Azerbaijan-Vietnam

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Update - Tax Treaty between Azerbaijan and Vietnam Signed

Officials from Azerbaijan and Vietnam signed an income tax treaty on 19 May 2014. The treaty is the first of its kind between the two countries.

Taxes Covered

The treaty covers Azerbaijan individual and corporate income tax, property tax, and land tax. It covers Vietnamese personal income tax, business income tax, agricultural land-use tax, and non-agricultural land-use tax.

Service PE

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

A permanent establishment will also be deemed constituted when a person conducts activities in a Contracting State (including offshore activities) related to the exploration for and exploitation of natural resources located in that State.

Withholding Tax Rates

  • Dividends - 10%
  • Interest - 10%
  • Royalties - 10%
  • Fees for Technical Services - 10%
  • Capital Gains - Gains from the alienation of immovable property, gains from the alienation of movable property forming part of the business property of a permanent establishment, gains from the alienation of shares or interests deriving directly or indirectly 50% or more of their value from immovable property located in a Contracting State, and gains from the alienation of shares in a company resident in a Contracting State may be subject to tax

Double Taxation Relief

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

Entry into Force and Effect

The treaty will enter into force once the ratification instruments are exchanged, and will apply from 1 January of the year following its entry into force.

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