Signed on July 7, 2015, the DTT and its Protocol will enter into force once ratified by the US and Vietnam.
A New Dawn, A New Day – The US Vietnam Double Tax Treaty – Salient Features and Practical Tax Planning Case studies
As a part of the comprehensive partnership enhancement between the United States (US) and Vietnam, on 7 July 2015, the two countries signed the first income tax treaty and the Protocol for the avoidance of double taxation and prevention of tax evasion/avoidance (Double Tax Treaty or DTT). The DTT and its Protocol will enter into force once ratified by the US and Vietnam.
The signing of the DTT and the negotiation of the Trans Pacific Partnership Agreement signals a new era in US-Vietnam relations. In this breakfast seminar, Jack Sheehan, Partner, Regional Tax Practice Group and Bernard Cobarrubias, Director, Regional Tax Practice, from DFDL will examine the role of the US-Vietnam DTT with respect to both US and Vietnamese investors.
During the session, Jack Sheehan, and Bernard Cobarrubias will provide an overview of the US-Vietnam DTT, highlighting the key articles for tax planning, and practical insights and case studies when using tax treaties in structuring cross-border transactions.
The session will include:
How the DTT can provide relief from Foreign Contractor Tax (FCT) in Vietnam.
How short term employees and secondees can be exempt from personal income tax under DTT.
Which articles of the DTT will apply to management and service fees and what relief is available.
An overview of Permanent Establishment rules and how it applies to business profits.
What relief is available to US/Vietnam withholding taxes on payments.
How the US Model DTT Limitation of Benefits (LOB) article and Vietnam’s General Anti Avoidance Rules (GAAR) can limit tax treaty relief to the unwary.
How capital gains on the sale of assets and shares are dealt with under the DTT.
Practical Case Studies: tax planning and structuring of cross border transactions.
|8:30 am||Registration & Breakfast Refreshment|
|9:00 am||Welcome Remarks|
|9:05 am||Presentation and Q&A|
|10:30 am||Event Ends|
Members: VND 500,000 | Non-members: VND 650,000
Jack Sheehan – Partner, Regional Tax Practice Group
Jack specializes in providing international tax planning and consulting, corporate structuring and restructuring, M&A and cross-border tax advisory services. He is advising clients in sectors ranging from telecommunications, mining, oil & gas, manufacturing, aviation, banking and financial institutions to government and aid-funded projects. Jack is a regular speaker at conferences and he and his team are contributors to international tax publications. Jack is a member of the Association of Chartered Certified Accountants in the UK.
Bernard Cobarrubias – Tax Director, Vietnam
Bernard has over twelve years of tax and legal experience in the Philippines, Vietnam and Myanmar. He also handles Lao and Cambodian tax engagements. Bernard specializes in international tax services with a focus on cross-border transactions, corporate restructuring, mergers and acquisitions advisory and implementation. He assists with local business tax advisory services, corporate structures and licensing as well as regulatory and tax compliance. Bernard holds a Bachelor of Laws degree and a Bachelor of Arts in Communications (Journalism) degree from the University of the Philippines.