Corporate income tax must be paid on capital transfer activities in Vietnamese companies that are held indirectly through other companies.

On February 27, 2024, the General Department of Taxation issued official letter No. 690/TCT-HTQT, stating that:

In the case where Company A in Japan holds over 25% of the total shares of a company in Vietnam through Company B and transfers all of those shares, the income from the share transfer activity of Company A is subject to Corporate Income Tax in Vietnam, as stipulated in the Tax Agreement between Vietnam and Japan.