Official Letter No. 4554/CT-CS dated October 21, 2025, issued by the Tax Department regarding the application of the Double Taxation Agreement (DTA) between Vietnam and France on loan interest income, as follows:

by KMC Consulting Company Limited

Accordingly, the Tax Agreement between Vietnam and France does not contain specific provisions governing income derived from loan interest. Interest income earned by the Bank does not fall under the category of “other income” as prescribed in Article 20 of the Tax Agreement between Vietnam and France.
Therefore, there is no basis for tax exemption on the Bank’s loan interest income under the provisions of the Vietnam–France Tax Agreement, and such interest income shall be subject to corporate income tax (CIT) in Vietnam in accordance with Vietnamese tax laws.

For more detailed information about this or related Tax Advisory, please don't hesitate to contact us.
Website: https://kmc.vn/
Hotline: +84 81 489 4789 or +84 91 988 9331
Email: info@kmc.vn