Official Letter No. CV910/CT-CS dated April 28, 2025 issued by the Tax Department regarding the application of the Vietnam-Germany Double Taxation Agreement to Connect Fund is as follows:

by KMC Consulting Company Limited

In the case where a foreign company generates income from lending activities in Vietnam under a bilateral loan agreement, such income is subject to Foreign Contractor Tax in accordance with Circular No. 103/2014/TT-BTC dated August 6, 2014 issued by the Ministry of Finance.

Interest income derived from loans in Vietnam and paid to the foreign company is not eligible for tax exemption in Vietnam under Point a, Clause 3, Article 11 of the Vietnam-Germany Double Taxation Agreement and Article 20 of Circular No. 205/2013/TT-BTC dated December 24, 2013 issued by the Ministry of Finance.

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