Recent guidance has been released, in the form of Circular No. 19/2011/TT-NHNN, specifying the process by which Vietnamese entities may issue international bonds, and the foreign exchange requirements arising from such issues. Corporate income tax and foreign contractor tax issues may arise as a result of international bonds issuances and more robust rules in this area may allow for new planning opportunities.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap