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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India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
ITR sat down for a pre-event interview with Tim Zech, WTS Germany, and Jeff Soar, WTS UK, keynote speaker at next week’s ITR AI in Tax Forum 2026 in London
India is signalling flexibility on expat taxation to attract foreign expertise, though employers will need to navigate disclosure, treaty and scope uncertainties