Treaty detail
China - Vietnam tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1995-05-17
Effective
1996-10-18
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 10% · Corporate rate: 10%
The China-Vietnam treaty generally applies a uniform cap on cross-border dividends without a separate parent-subsidiary rate. The precise outcome still depends on beneficial ownership and Article 10.
Interest
Rate: 10%
Interest paid to or guaranteed by the government or central bank of either state is typically exempt. Other categories follow the standard 10 percent cap.
Royalties
Rate: 10%
Royalty treatment under this treaty caps the source-country rate at 10 percent for most categories. Practitioners should still confirm the specific royalty type against Article 12.
Permanent establishment
Construction threshold: more than 6 months
Dependent-agent rules apply where a person habitually concludes contracts or maintains a stock of goods on behalf of the enterprise.
Other treaty flags
Pension taxation is generally allocated to the residence state, with separate rules for government-service pensions.
Seeded article summaries
Article 4
Residence
Defines treaty residence and is the gateway to any benefit under the treaty.
Residence under the China-Vietnam treaty matters in particular for Chinese investors operating in Vietnam's manufacturing zones and for cross-border employment arrangements.
Article 5
Permanent Establishment
Sets the business-presence threshold with a services-PE element.
The China-Vietnam treaty includes a construction threshold and a separate services threshold, which is typical of treaties between China and other developing economies.
Article 7
Business Profits
Reserves business profits to the residence state absent a permanent establishment in the other state.
Article 7 is the operating rule for cross-border supply chains, contract manufacturing arrangements, and consulting services flowing between China and Vietnam.
Article 10
Dividends
Caps source-country withholding on cross-border dividends at a uniform rate.
Article 10 produces a uniform treaty cap regardless of shareholding percentage. The dividend article should be read together with Vietnamese and Chinese domestic withholding rules.
Article 11
Interest
Caps source-country withholding on cross-border interest with government-interest carve-outs.
Article 11 caps the general rate at 10 percent. Government-related and qualifying financial-institution interest may be fully exempt under the article.
Article 12
Royalties
Caps source-country withholding on royalties at a uniform rate.
The royalty article matters for cross-border technology transfer, manufacturing licenses, and software. The precise rate should be confirmed against Article 12.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–CN treaty
- TreatyGB–CN treaty
- TreatyCA–CN treaty
- TreatyAU–CN treaty
- TreatyCN–DE treaty
- TreatyCN–JP treaty
- TreatyCN–IN treaty
- TreatyCN–SG treaty
Primary sources
- China State Taxation Administration - tax treatiesVerified 2026-05-20
- Vietnam General Department of Taxation - internationalVerified 2026-05-20
- OECD MLI signatories and partiesVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.