|
|
|
|
|
|
|||||
      
|
1997-104
Tax Agreement Signed by Canada and the Socialist Republic of Vietnam
Related document:
Finance Minister Paul Martin today announced that an Agreement between Canada and the Socialist Republic of Vietnam for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income was signed on November 14, 1997, at Hanoi. The Agreement was signed on behalf of Canada by the Minister for International Cooperation, Diane Marleau, and on behalf of the Socialist Republic of Vietnam by the Minister of Finance, Nguyen Sinh Hung.
The Agreement is patterned to a large extent on the model double taxation convention prepared by the Organisation for Economic Co-operation and Development. Under the Agreement, a general rate of withholding tax of 5 per cent will apply to dividends paid to a company that controls at least 70 per cent of the voting power in the company paying the dividends. For a company that controls at least 25 per cent but less than 70 per cent of the voting power in the company paying the dividends, a 10 per cent withholding tax will apply. A rate of 15 per cent withholding tax will apply in all other cases.
The Agreement additionally provides that the rate of the branch tax will be reduced to 5 per cent. A reduced rate of withholding tax of 10 per cent will also apply to interest and to royalties and a 7.5 per cent withholding tax will apply to fees for technical services. The Agreement also provides for a number of exemptions in the case of interest and a most favoured nation provision in the case of certain royalties.
The Agreement will enter into force after Canada and the Socialist Republic of Vietnam have notified each other of the completion of the procedures required for its bringing into force and its provisions will have effect from the first day of January of the year following the entry into force.
___________________
For further information:
Jean-Marc Déry
Tax Legislation Division
(613) 992-1862
|
|
||||
| Last Updated: 2005-01-04 |
|
||||
