It’s an undisputed fact that globalization has led the change in trends and diversity of options while doing business. At Grant Thornton Vietnam, we understand those trends as well as the potential impacts and risks of international taxation while expanding your business globally. Having said that, our International Tax practices are developed, which aims to establish the most efficient international tax strategies among multi-national entities.

We strive to maximize your tax benefits while minimizing any tax risks associated with your business on a global scale and assist you in planning your legal structure, repatriation planning, and exit strategies. Our expertise comes from not only our extensive local knowledge but also leveraging the available resources from our network of member firms around the world. Ultimately, we plan the route for your global growth, as precise as possible.

Approaches and Services:

Your business: How to avoid international tax issues on cross-border transactions.

Service 1: Review of contracts including cross-border transactions & advice on tax implacations 

Provide an overview of Foreign Contractor Tax legislation governing the transaction;

Analyze both domestic legislation and the available tax treaties;

Recommendation for tax planning to achieve tax efficiency and mitigate tax risks.

Timeline: 2 weeks

Deliverable: A written report covering analysis and recommendations

Service 2: Analysis of permanent establishment ("PE") issues 

Comment on the PE risks that the offshore entity may have through the nature of works handled by a Vietnamese entity/ individual;

Comment on tax implications in the event that the Vietnamese entity/ individual being considered as a PE of the offshore entity;

Recommendations to mitigate the PE risk.

Timeline: 2 weeks

Deliverable: A written report covering analysis and recommendations

Your business: Optimize international tax benefits.

Services 3: Preparation of the avoidance of double taxation agreement (“DTA”) application

Review the transaction;

Analyze both domestic legislation and the available tax treaties;

Prepare all required documentation;

Review and ensure that DTA dossier and documentation comply with the prevailing regulations.

Timeline: 3 weeks

Deliverable: A package dossier required for DTA application.

Your business: Appeal for unfavorable treatment

Service 4: Tax petition

Draft/ submit petition letter;

Follow up to have meetings with authority;

Assist in explanation of issues with supportive arguments to seek a favorable treatment.

Timeline: 3-8 weeks.

Deliverable: The official reply to the authority.

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