Tax period (from ... to ...)

Taxable period (from ... to ... on ...)



 





Tax (tax payable) in which (of which):-real tax payable (Actual tax due):-tax Number is reduced (Reduced amount): tax Number was filed (Tax paid): according to the regulations of the relevant tax law According to the relevant provisions of tax law tax/thànhphố................. confirmed currency (and/or the long, steady) sốthuế of income tax payers.

It is herebycertified that the Taxation Department of ... ... has received (and/or grantedthe exemption, the reduction of) the mentioned income tax amount from (to) theabove taxpayer.

                                                                                                Cụctrưởng taxation.........

Director of the Department of Taxation.......

(Signature and stamp)-Signedand sealed Annex B of the TAX BUREAU of the SOCIALIST REPUBLIC of VIETNAM SOCIALIST REPUBLIC OF VIETNAM GeneralDepartment of Taxation Taxation.................. Independence-freedom-happiness Department ofTaxation of........... Independence-Freedom-Happiness (No.):------------------------------------..., (day) day month (month) (year) CERTIFICATE HAS FILED INCOME TAX RETURNS for INCOME TỪTIỀN the COPYRIGHT or FROM INTEREST of MONEY LENDING or TRANSFERRING INCOME OFFSHORE CERTIFICATE OF TAX PAYMENT ON ROYALTY OR INTEREST OR REMITTED INCOME dear:.................................................................

             To tax/thànhphố................. confirmed currency (and/or the long, steady) sốthuế of income tax payers here for income from: The Department of ofTaxation......... certifies that it has received (and/or granted the exemption, the reduction of) the income tax amount from (to) the following taxpayer inrespect of income: royalty lending money Interest ă ă ă outward transfer income Royalty Interest Remitted income subject really enjoy (beneficialowner) name (Name):........................................................................................ Address (residence of doanhhoặc):........................................................

Address (of businessor residence place) tax code (or mail/chứngminh hộchiếu):.............................................................

Number of tax indentification (or i. d. card/passport) to be uỷquyền receive income (in any case not the real audience enjoy) Designated person asbenificiary (other than the beneficial owner) name (Name).................................................................................................................... Address (residence of doanhhoặc):........................................................

Address (of businessor residence place) tax code (or chứngminh letter/passport):.............................................................

Number of taxindentification (or i. d. card/passport) of object paid thunhập (Incomepayer) name (Name).................................................................................................................... Address (residence of doanhhoặc):........................................................

Address (of businessor residence place) tax code (or mail/chứngminh hộchiếu):.............................................................

Number of taxindentification (or i. d. card/passport) why pay thunhập (reasonfor which the payment is made):....................................................................

....................................................................................................................................

....................................................................................................................................





 

Income tax (Tax payable) on taxable Taxable income tax filing Of tax (Total of tax payable) actual tax payable (Actual tax due) are tax exemptions (Exempted or reduced amount) (Due date) have filed (Tax paid) xxx xx xx xx xx xx Chief tax.........

Director of Taxation Departmentof.......

(Signature and stamp)-Signed and sealed Appendix C of the TAX BUREAU of the SOCIALIST REPUBLIC of VIETNAM SOCIALIST REPUBLIC OF VIETNAM GeneralDepartment of Taxation Taxation.................. Independence-freedom-happiness Department ofTaxation of........... Independence-Freedom-Happiness (No.):------------------------------------..., (day) day month (month) (year) RESIDENT CERTIFICATE CERTIFICATE OF TAX RESIDENCE dear:.................................................................

             To: tránhđánh agreement base double taxation and prevent tax evasion with respect to taxes on income between Vietnam and đánhvào.. ... .. ... ..., City/province tax Bureau................. certified tax payers here is for tượngcư stay under the tax level in the sense of the tax year..............................................................

Pursuant to theAgreement between Vietnam and...... for the avoidance of double taxation and theprevention of fiscal evasion with respect to taxes on income, the Department ofTaxation of ... .. ceritifies that the following taxpayer is a resident for thetax purposes in Vietnam for the tax year (s) of...........         

Tên(Name)....................................................................................................................

Địa chỉ (kinh doanhhoặc nơi cư trú) : ........................................................

Address (of businessor residence place) tax code (or mail/chứngminh hộchiếu):.............................................................

Number of taxindentification (or i. d. card/passport) Bureau Chief taxation.........

Director of Taxation Departmentof.......

(Signature and stamp)-Signed and sealed ANNEX of 26 agreements between Vietnam and I-we-li-a (attached to circular No. 36/2000/TT/BTC dated May 5, 2000 5năm of the Finance Ministry, revising, supplementing circular No. 95/1997/TT/BTC dated 29 tháng12 in 1997 by the Ministry of Finance) Although there are quiđịnh in circular No. 95/1997/TT/BTC dated 29 December 1997 of the Ministry of finance , the following guidelines will be applied in the case of implementation of Hiệpđịnh between the Government of the Socialist Republic of Vietnam and the Government of the Republic nướcCộng the I-I-li-a about avoiding the taxed twice and prevent evasion of income tax thuếđối with effect from December 20, 1999 , and đượcáp for taxes in Vietnam from December 1, 1996 1. Income from tiềnlãi shares: Under item 2 Article 10của of this agreement, the tax limits stated in point 5.2 paragraph 5 section II tưlà Information: a. 5 percent of the total amount of interest rate phầnnếu neck real object is a company (other than the partner organisation), check out the next soáttrực at least 70% of the capital of the company paying the interest on the shares;


b. the total amount of 10 percent of interest phầnnếu stock the real object is a company (other than the partner organisation), check out soáttrực from 25 percent to 70 percent of the capital of the company paying the interest on the shares;

c. 15 percent of interest shareof all other cases.

2. Income from lending money lãitừ: 2.1 according to clause 2 of this agreement Điều11, the tax limits stated in point 6.2 account 6 section II củaThông investment is 10% of the total amount of interest from money lenders;

2.2 interest rate from funds generated from source chovay Vietnam will be tax free in Vietnam if: a. the loan interest paid object is phủViệt or local government agencies of Vietnam;

b. the interest from the loan funds are paid to the Chínhphủ of I-we-li-a local government body or of I-we-li-a kỳmột or any agency or organization (including a financial institution) by the nướcI-I-li-a or the local Government of I-we-li-a whole property; or c.         interest from money lenders to be charged for any kỳmột agency or other organization (including a financial institution) that the khoảnvay made under an agreement to be signed between Vietnam and I-we-li-a.

3. Revenue from tiềnbản rights and technical service fee: 3.1 under the địnhnày, the text of point 6.3 paragraph 6 section II additional circular definition vềPhí technical services are as follows: the term "phídịch engineering" is used in this Article means payments of any kind under beats paying for an object except for payments for the ngườilàm of object paid for any service would bring the nature management, consulting, engineering is done in countries that are paid for tượngcư objects.

3.2 according to clause 2 of this agreement Điều12, the tax limits stated in point 7.2 clause 7 section II: a. Thôngtư 10 percent of the total amount of copyright;

b. the 7.5 percent of the total amount of fees vụkỹ.

4. Return of property alienation từchuyển: according to the content of article 13 paragraph 4 địnhtại fiend this agreement the taxes for income from chuyểnnhượng the property referred to in clause 8 section II circular also applies in trườnghợp transfer of stock in a company is subject to a Nướcký the , provided the transfer object holds a minimum of 25% of the stock capital of the company phầncủa.

5. other income: according to tạikhoản rules 3 Article 22 of the Convention, the case because of the special relationship between the types of conduct the activities give rise to income as stated in paragraph 17 of the circular mụcII, the amount to be charged for activities which exceed the amount of the đượcthoả agreement between the independent object then the outstanding payment will bịđánh countries where taxation in born under the law of the country of income that cóxem proper consideration to the other provisions of this agreement.

APPENDIX No. 27 agreement between Vietnam and In-measure-United Kingdom-a (attached to circular No. 37/2000/TT/BTC on May 5, 2000 5năm of the Finance Ministry, revising, supplementing circular No. 95/1997/TT/BTC dated 29 tháng12 in 1997 by the Ministry of Finance) Although there are quiđịnh in circular No. 95/1997/TT/BTC dated 29 December 1997 of the Ministry of finance , the following guidelines will be applied in the case of implementation of Hiệpđịnh between the Government of the Socialist Republic of Vietnam and the Government of the nướcCộng Republic In-measure-United Kingdom-a about avoiding the taxed twice and prevent escape lậuthuế for income tax to take effect from February 10, 1999 đượcáp for taxes in Vietnam from July 1, 2000.1. Thườngtrú: base 1.1 required tạikhoản 3. b article 5 of this agreement time forming the basis for permanent active miners to provide services referred to in point 3.2. c paragraph 3 section I of circular là3, during the period of 12 consecutive months.

1.2 according to the địnhnày, the paragraph 3.2. e circular section I paragraph 3 is replaced by the content of the active object: địnhsau qui độngthay face for a factory.         there and regularly perform at the water đóthẩm the right to negotiate and sign contracts on the enterprises, except when the unAmerican activities of that object only to prepare or support as the unAmerican activities referred to in point 3.3 of the circular;

b. not authorized as aforesaid, nhưngthường regularly maintained in Vietnam a warehouse the goods or property through the trans-đóthường delivered the goods or property on behalf of the enterprise;

c. production and processing in Vietnam for the accreditation of the goods or property belonging to the enterprises.

1.3 under the nàycác operating costs of insurance or insurance (except for reinsurance) ro cácrủi in Vietnam territory of foreign insurance companies do object quacác information or representation is not the dealer has the status độclập be deemed to have a permanent base in Vietnam.

2. in income: required tạikhoản 1 b and c of article 7 of this agreement, a foreign enterprise, not the tax chỉchịu in Vietnam to account revenues allocated for permanent cótại Vietnam base as stated at clause 2 section II of the circular, which also taxed đốivới both benefit allocated for activities sold the goods or property , or phânbổ for business activities conducted in Vietnam, identical or similar goods or vớitài, or business activities are conducted through sởthường stay there in Vietnam.

3. liênkết Enterprise: according to the tạikhoản rules 3 article 9 of this agreement, the time limits make the adjustment back to the giágiao room between the enterprises affiliated to suit the trading price between two independent accreditation referred to in clause 4 section II of the circular will not exceed hiệuqui in the internal law of each State.

4. Revenue from tiềnlãi shares: Under item 2 Article 10của of this agreement, the tax limits stated in point 5.2 paragraph 5 section II tưlà Pine 15 percent of equity interest;

5. Income from lending money lãitừ: 5.1 according to clause 2 of this agreement Điều11, the tax limits stated in point 6.2 account 6 section II củaThông is 15% of the total amount of interest from money lenders;

5.2 the interest from the money chovay arose from Vietnam will be tax free in Vietnam if: a. the pay to the Government of Ireland-United Kingdom-a baogồm all local authorities, government agencies củaIn-base-xi-a;

b. pay the Central Bank or any financial kỳtổ would do In Government-a-control and hànghay Bank's capital this financial institution wholly owned by the Government In United Kingdom-xi-a, depending on the time agreement between the competent authorities in the South and củaViệt In Nepal.

6. Income from tiềnbản rights: 6.1 according to clause 2 of this agreement Điều12, the tax limits stated in point 7.2 clause 7 section II Thôngtư is 15 percent of the total amount of copyright;

 7. Income from the transfer of nhượngtài products: according to the content of paragraph 5 of article 13 địnhtại fiend this agreement the taxes for income from chuyểnnhượng the property referred to in clause 8 section II circular also applies in trườnghợp transfer of stock in a company is a resident of a Nướcký object.

8. Income from independent personal services unAmerican activities: as required tạikhoản 1. b article 14 of this agreement the time limit for the right to collect the thuếthu type from the activities of independent personal service made at 9.3 and 9.4 points account nêutại Vietnam 9 section II of the circular is 90 days instead of 183 days nhưđã stated.

9. Income from dependent personal services unAmerican activities:


According to the tạikhoản rules 1. Article 15 of this agreement a time limit for the right to collect import thuếthu from the personal service activities depends made in Vietnam nêutại paragraph 10.2. a paragraph 10 section II of the circular is 90 days instead of 183 days as đãnêu.

10. từtiền: pension income as defined tạikhoản 1 Article 18 of this agreement, the income sources of water where the money lươnghưu stated in point 13.1 account 13 section II of the circular can collect taxes for this type thunhập.

11. other income: as defined in Điều22 of this agreement, the types of other income referred to in clause 17.1 points 17 circular IIcủa items may be taxed in the country where the income arises. In trườnghợp where the income arises is the Vietnam Vietnam can collect taxes for this entry cácthu.

 

           

ANNEX of 28 agreements between Vietnam and Ca-na-đa (accompanied by circular No. 37/2000/TT/BTC on May 5, 2000 5năm of the Finance Ministry, revising, supplementing circular số95/1997/TT/BTC dated 29 December 1997 of the Ministry of Finance) Although there were quiđịnh in circular No. 95/1997/TT/BTC dated 29 December 1997 of the Ministry of finance , the following guidelines will be applied in the case of implementation of Hiệpđịnh between the Government of the Socialist Republic of Vietnam and the phủCa Canada about avoiding the taxed twice and prevent tax evasion for income tax cácloại is valid from December 16, 1998 and was ápdụng for taxes in Vietnam from July 1, 1999:1. The from ngữchung: the term "object" includes individual, partner organizations, companies and any other organization, including gồmcả a legacy or trust.

2. thườngtrú facility: 2.1. According to địnhnày, the paragraph 3.2. a circular section I paragraph 3 is replaced by the following provisions: a. which has business in Vietnam: sởđiều head office, branches, offices (including the Office of trade representatives of foreign thươngnhân in Vietnam in case of authorized signing đồngthương) , plant, factory, mine, oil or gas wells, quarries or kỳđịa any other point related to the exploration or exploitation of resources thiênnhiên.

2.2. According to the địnhnày, an organization of insurance object is the residence of the Ca-na-đa if done thuphí insurance in Vietnam or perform hedging in Vietnam through quamột objects have no independence, except in the case of reinsurance, will đượccoi be made doing business in Vietnam through a thườngtrú facility in Vietnam.

3. Income from the business of unAmerican activities: under this agreement, no benefit would be allocated to a permanent base of a Ca's accreditation Canada in Vietnam if permanent basis which merely buy hànghóa or property for the enterprises.

4. Determine the beneficial tax tứcchịu of affiliate enterprises: under this agreement, the income of an enterprise as guided in circular IIcủa item 4, clause will not apply after the expiry of the regulation in the luậtquốc and in any case, after five years from the last day trongnăm that income earned by enterprises should bear adjust, however quiđịnh does not apply in the case of fraud, attempted fraud or neglect.

5. Income from tiềnlãi shares: Under item 2 Article 10của of this agreement, the tax limits stated in point 5.2 paragraph 5 section II of Thôngtư is 5%; 10% and 15% according to the specific case as follows: a. 5% of the total amount of lãicổ part if the real object is a company that controls at least 70% of the bỏphiếu rights of the company to pay interest on the shares;

b. 10% of the total number of tiềnlãi shares if the real object is a company that controls at least 25% nhưngdưới 70% of the voting power of the company paying the interest on the shares;

c. 15% of the total number of tiềnlãi shares in all other cases.

6. Income from lending money lãitừ: 6.1 according to clause 2 of this agreement Điều11, the tax limits stated in point 5.2 paragraph 5 section II Thôngtư is 10% of the total amount of interest from money lenders.

the Vietnamese case 6.2 taxes for income from interest of money by lending institutions, cánhân Vietnam charged to objects of interest from foreign funds for vaytrả for the Government of Ca Canada, or payable to the Government premises or local chínhquyền of Ca-na-đa will be tax free in Vietnam or if clause lãinày was charged in relation to the loan are guarantee or insurance bởibất States that an organization which differed from the organization by the Ca-na-đa toànbộ property and agreed in letters exchanged between the competent authorities quyềncủa Vietnam and Canada also will be tax free in Vietnam.

7. Income from tiềnbản technical services and fees: Under item 2 Article 12của of this agreement, the tax limits stated in point 7.2 clause 7 tưlà Information section II 10% of the total amount of royalties.

According to clause 2 of this agreement, the 12của thing in the case of technical service fees incurred in Namtrả for an audience of Ca Canada and if the service charges received objects technique is real audience enjoys the tax rates are calculated in Vietnam won't exceed 7.5% of the total amount of the fee.

8. Income from pension tiềnlương: according to paragraph 2 Article 18của of this agreement, the amount of pensions arising in Vietnam was a resident of object trảcho Ca-na-đa may also be taxed in Vietnam. However in the case of periodic pension payments, in addition to the monies were paid under the social insurance law in Vietnam the tax rates are calculated, in Vietnam it won't too 15% of the total funds.

9. other income: under this agreement, clause 17 circular section II is replaced by the following: rule 17.1. Article 21 tax quiđịnh for yet another earnings mentioned in cácđiều of the Treaty.

17.2. According to article 21, địnhtại the case of a resident of Vietnam object has the nhậpkhác revenues as mentioned in point 17.1, regardless of where they arise will only have to pay tax in South tạiViệt (or which is the object of Ca Canada, then will just have to pay tax tạiCa Canada).

 

ADDENDUM of 29 agreements between Vietnam and Belgium (accompanied by circular No. 36/2000/TT/BTC dated May 5 năm2000 of the Finance Ministry, revising, supplementing circular No. 95/1997/TT/BTC ngày29 December 1997 of the Ministry of Finance) Although there were quiđịnh in circular No. 95/1997/TT/BTC dated 29 December 1997 of the Ministry of finance , the following guidelines will be applied in the case of implementation of Hiệpđịnh between the Government of the Socialist Republic of Vietnam and the Government of Belgium Vươngquốc avoid taxed twice and prevent tax evasion for thuếđánh on income and assets in effect from June 25, 1999 and was ápdụng for taxes in Vietnam from 1 January 2000:1. Thườngtrú basis: under this agreement, paragraph 3.2. a paragraph 3 of the circular section I is replaced by the following provisions: a. which has business in Vietnam: sởđiều head office, branches, offices (including the Office of trade representatives of foreign thươngnhân in Vietnam in case of authorized signing đồngthương) , factory, warehouse, factory, mine, oil well or gas, mine đáhoặc mining locations or natural resource exploration.

2. Income from the business of unAmerican activities: 2.1. According to địnhnày, no benefit would be allocated to a permanent base of mộtxí of Belgium in Vietnam if permanent basis which merely buy hànghóa or property for the enterprises.


2.2. According to the địnhnày, in relation to paragraph 1 article 7, interest that a Belgian firm obtained từviệc buy or sell the goods of the same kind or similar to the goods being bánthông through resident establishments in Vietnam, or from the implementation of the joint operations of the same kind or similar operations are performed through permanent facility quacơ in Vietnam , will be allocated for permanent basis that if xácđịnh is that this transaction was made for the purpose of avoiding tax in Vietnam.

2.3. According to địnhnày, related to the tax and the allocation of taxable income to a thườngtrú basis of a Belgian company in Vietnam referred to in paragraph 1 and 2 of article 7, in high survey contracts, supply, installation or construction of security entrance control equipment for industrial, commercial or scientific , or warehouses, or for the public benefit, côngviệc allocation for resident establishments in Vietnam that this basis thôngqua the company of Belgium performs its business activities in South tạiViệt will be calculated on the basis of the part of work of the contract that the basis of that thườngtrú made.

5. Income from tiềnlãi shares: Under item 2 Article 10của of this agreement, the tax limits stated in item 5.2 points II circular là5%, 10% and 15% of the total amount of the interest shares according to each case, as follows: (a) 5% of the total amount of the interest if the shares for tượngthực is a company that holds directly or indirectly at least 50% of the capital củacông company paid interest of shares;

(b) 10% of the total amount of the interest if the shares for tượngthực is a company that holds directly or indirectly at least 25% but dưới50% of company capital stock paid interest;

(c) 15% of the total amount of the interest shares in all other cases.

The limits of this thuếsuất including tax profit transfer abroad of Vietnam.

6. Income from lending money lãitừ: according to clause 2 of this agreement 11của, the tax limit stated in point 6.2 section II circular of 10% of the total amount of interest from money lenders.

Free case namđánh of income tax in respect of the interest from the loan money due the Organization, Vietnam cánhân pay for the residence of the foreign object, interest rate from funds for vaysẽ are tax free in Vietnam if: (i) that the Belgian Government doChính interest, an agency or local government in Belgium to receive and enjoy; or (ii) interest that doNgân the Central row of Belgium or any an organization that its capital due to Belgian Chínhphủ or an agency or the local Government of Belgium the entire property, real nhậnvà;

7. Income from tiềnbản right: 7.1. According to clause 2 of this agreement Điều12, the tax limits stated in point 7.2 clause 7 section II Thôngtư is 5%, 10% and 15% of the total royalties depending on each case nhưsau: a. 5% of the total amount of bảnquyền if a royalty is charged for the use or right to use the invention by means of dụngbất , design or model, plan, process or formula bímật, or charged for the information related to the industry experience or khoahọc;

b. 10% total tiềnbản rights if royalties are paid for the use of or the right to sửdụng trade marks or information regarding business experience;

c. 15% of the total number of tiềnbản rights in all other cases.

7.2. However in high where a resident of Belgium objects to perform the technical services thuậttại activity in Vietnam and have no permanent base or fixed base in Vietnam thìkhi that this income will not exceed 5% of the taxable only in Vietnam.

15. củasinh-income, vocational students: under this agreement, 15.2. clause 15 section II b of circular provisions is replaced by the following: b. Income sinhviên or interns receive from work in Vietnam trựctiếp relevant to learning activities, training in Vietnam will not be taxed in Vietnam with the condition that income does not exceed the amount Vietnam is equivalent to 120,000 Belgian Francs per year.

16. củagiáo-income students, professors and researchers: the rule in clause 16mục I of the circular on the income of teachers, professors and people nghiêncứu not apply in this agreement.

17. other income: under this agreement, clause 17 circular section II is replaced by the following: rule 17.1. Article 21 tax quiđịnh for yet another earnings mentioned in cácđiều of the Treaty;

17.2. According to article 21, paragraph 1 địnhtại the case of a resident of Vietnam object has the khoảnthu enter as mentioned in point 17.1, regardless of where they arise will just have to nộpthuế in Vietnam (or which is the object of Belgium will only have to submit the thuếtại Belgium);

17.3. Govs địnhtại item 2 article 21, if an object resides in Belgium have other income in Vietnam and conducted operations in Vietnam through a thườngtrú facility in Vietnam, or to perform the activities of independent personal service thôngqua a fixed facility in Vietnam and the right or property contains the nhậpkhác revenues are charged the actual contact with permanent base or fixed to another facility when that other earnings are tax free in Vietnam that ápdụng according to the stipulation in article 7 and article 14 business income độngdịch independent personal services Activities./.