Capital Assignment Tax – Offshore Indirect transfer

OVERSEAS
• Offshore indirect transfer – rendered
outside Vietnam between 2 overseas FRANCE
Company B share sold to
companies, who indirectly hold interest Company D
in Vietnam company. Company A

100% own
UK
• Transfer considered as generating tax
profit from Vietnam  CAT Company D

NETHERLAND 100% own

• Tax calculation basis – deem/gain,
who/when?
Company B

• Tax treaty application – unclear

100% own
VIETNAM

Company C