Future of Vietnam DTAs post-MLI

23 February, 2022

On 9 February, Vietnam signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“the Convention” or “the MLI”), becoming the 99th jurisdiction to join the Convention.

This is a milestone in the course of the implementation of the BEPS Action Plan in Vietnam after Vietnam became the 100th member of the BEPS Inclusive Framework 5 years ago.

As a result, potentially 75 of Vietnam’s double tax agreements (”DTAs”) could be altered once the MLI comes into effect. Taxpayers should be aware of these potential changes to DTAs and the impact this may have on their plans for structuring their investments and transactions to claim treaty benefits in Vietnam.

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Get in touch

Nguyen Thanh Trung

Partner, Tax and Legal Services Leader, PwC Vietnam

Tel: +84 28 3823 0796

Nguyen Huong Giang

Partner, Tax Services, PwC Vietnam

Tel: +84 24 3946 2246

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