South Korea And Vietnam Sign Revised Protocol To Avoid Double Taxation Agreement

According to the Ministry of finance of South Korea, South Korea's foreign minister, Kang Jing, and the "Korean Vietnam summit" held in Seoul in November 27th (2019) in November 27th, signed the revised protocol on "South Korea Vietnam avoidance of double taxation agreement" with Vu Thi Mai, the deputy head of Vietnam's finance department. After signing the agreement on the avoidance of double taxation agreement between South Korea and Vietnam, the Korean enterprises' investment in Vietnam increased rapidly. The two governments decided to amend the avoidance of double taxation agreement in line with the rapid growth of the two countries' economic relations, lighten the tax burden and improve the investment environment of Vietnam's investment in Vietnamese enterprises. The revised protocol signed by the two governments will come into force after the two countries' Congress has passed the examination and approval.

The "South Korea Vietnam avoidance of double taxation agreement", which is revised, includes:

(1) income derived from the fixed establishment of a business establishment: the scope of the business income stipulated by the taxable object engaged in building activities. It is clearly stipulated that the activity of belonging to a fixed construction business site shall be regarded as the object of taxation.

(two) the scope of the international transport business: the scope of the duty free international transport will include the use, maintenance, management and rental of the container.

(three) proceeds from royalties: the income of 15% of the royalties currently applied (intellectual property rights and trademarks of cultural, artistic and scientific works) will be reduced to 10% of the maximum applicable tax rate in the country of origin.

(four) the new technical service fee: the income from services, technology and consulting services can be taxed in the country of origin (the highest applicable tax rate is 7.5%).

(five) the proceeds from the transfer of shares: real estate shares and stockholders who hold more than 15% of the shares can be taxed in the country of origin.