TAXATION

Notable Tax Matters

Undisclosed foreign oil company
Detailed analysis, evaluation of its production sharing agreements and applicable law throughout a period exceeding 25 years to determine its entitlement to accumulated tax incentives from the Government in a dispute submitted to international arbitration. 

Thermtrol (VSIP) Company Ltd
Successfully assisted to handle a corporate tax dispute (with multi-million-dollar claim) with local tax authorities as related to capital gains tax; and continue to advise the Parent on tax matters arising from its structuring plan. 

II-VI Vietnam Co
Successfully assisted client to handle a corporate tax dispute with local tax authorities, arising out of previous tax incentives granted under its investment project. 

Nippon Signal
Assisted client to address tax matters (foreign contractor tax and personal income tax) in relation to the Ho Chi Minh City Urban Railway Construction Project where Nippon Signal is a subcontractor under Vietnamese tax regulation and the Vietnam-Japan Tax Treaty. 

Numerous undisclosed multinationals
Assist in tax issues arising from assignment to and return from Vietnam of foreign employees. 

dLocal Group Limited

Advised on various taxes that relate to cross-border transactions, intermediate payment services, corporate structure, and business arrangements with a local partner. 

Tata Group
Prepared a report on tax matters applicable to the automobile industry to assist Tata to assess strategy for market entry. 

First Vietnam Joint Stock Company
Assisted to restructure itself for tax purposes in connection with a proposed M&A transaction with Aeon. 

Group of well-known multinational FMCG corporations
Successfully assisted to advocate against imposition of a form of excise tax. 

Undisclosed foreign bank
Assisted client to shape the application of the foreign contractor tax to its operational structure. 

Saigon Premier Container Terminal
Assisted (an 80/20 joint venture between DP World and IPC) to obtain tax exemption under the Vietnam-France Tax Treaty. 

Siam IKK
Assisted client to review documents, agreements and activities to address tax risks and exposure. 

British American Tobacco
Provided analysis of its corporate tax dispute with local tax authorities, arising from tax incentives granted under its investment project. 

CAE S.p.A
Advised on foreign contractor taxes and corporate income taxes that arise from an agreement with a Vietnamese partner namely “Hydro-Meteorological Observation Center” under the Vietnam-Italian Tax Treaty.

Pacifico
Advised on corporate structure, project formation, tax and investment incentives for solar and wind projects; conducted due diligence investigations for proposed investment in solar projects in Ninh Thuan Province, (30MW) and two additional solar power projects (50MW and 40MW) in Binh Thuan Province. 

Ranemoi Energy Pte Ltd
Advised on basic business model, corporate structure and applicable taxes for wind and solar projects then under consideration.

Undisclosed Foreign Fund

Advised on capital gains tax that may arise from an indirect transfer of shares, and possible solutions to mitigate tax implications.

Undisclosed Foreign Client

Advised on PE exposure that may arise from arrangements between the client and its “employee” under Vietnam tax regulations and Vietnam-Singapore Tax Treaty; and provided suggestions to mitigate tax risks.