Guidance on determination of permanent resident establishment

On July 30, 2015, Tax Department of Bac Ninh province issued Official Letter No. 1559/CT-TTHT providing guidance on determination of permanent resident establishment. Accordingly, in case, Company A is the resident permanent establishment in Korea, signs contracts with Company B in Vietnam, and authorizes B to deliver/receive goods to/from enterprises in Vietnam under on-sport imports and exports.  A is considered to have a resident establishment in Vietnam, and not exempted from FCT under double tax avoidance agreement between Viet Nam and Korea. The income received from A for providing goods to other company in Vietnam must be imposed on FCT.