Circular 205 on the implementation of tax treaties

Circular 205/2013/TT-BTC (Circular 205) dated 24 December 2013 has been issued on the implementation of tax treaties. Circular 205 provides rules on the applicability of tax treaty benefits and general anti-abusive provisions (GAAR) and is effective from 6 February 2014. The most salient changes in Circular 205 from the previous circular on the implementation of tax treaties (Circular 133 issued in 2004) are the introduction of GAAR and the beneficial ownership provisions. The key points of Circ…