Based on Double taxation avoidance agreement, Circular 205/2013 / TT-BTC dated 24/12/2013, Circular 219/2013 / TT-BTC dated 31/12/2013, Circular 78/2014 / TT-BTC dated 18/6/2014, Circular 96/2015 / TT-BTC dated 22/6/2015 and Circular 151/2014 / TT-BTC dated 10/10/2014, in case Company A is operating in South Korea (the foreign contractor - the transferor) signs the capital transfer contract in Company B (the company is in Vietnam) to Company C (the transferee), the declaration and payment of VAT and CIT from the capital transfer of Company B are made as follows:
1. Subject to tax on the income from capital transfer: Company A
2. Responsibility for tax declaration and payment: Company B must register, declare and pay taxes on behalf of Company A.
3. Determination of payable VAT and CIT amount: