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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Vietnam: Dividends

The Vietnamese tax deducted from dividends at the agreement rate of 15 per cent (or 7 percent where the recipient is a United Kingdom company which controls, directly or indirectly, at least 50 per cent of the voting power in the company paying the dividends or which has invested at least £7m in the share capital of the company paying the dividends; or 10 per cent where the recipient is a United Kingdom company controlling, directly or indirectly, at least 25 per cent but less than 50 per cent of the voting power in the company paying the dividends) qualifies for credit as a direct tax (see INTM164010(c)).

These reduced rates do not apply if the dividends are effectively connected (see INTM153110, fifth sub-paragraph) with a business carried on through a permanent establishment or fixed base which the recipient has in Vietnam.

A United Kingdom company controlling, directly or indirectly, at least 10 per cent of the voting power in the Vietnamese company paying the dividend is entitled, under Article 22(1)(b) of the agreement, to credit for underlying tax (see INTM164010(d)).