According to instructions at Official dispatch 39624/CTHN-TTHT 2022 about CIT for capital transfer activities, the Hanoi Tax Department answers as follows:

- In case a foreign organization generates income originating from Vietnam from capital transfer activities, it is subject to corporate income tax in Vietnam.

- In case the transferee of capital is also a foreign organization that does not operate under the Investment Law or Enterprise Law, the enterprise established under Vietnamese law where the foreign organization invests capital is responsible for declaring and Pay on behalf of the corporate income tax payable from capital transfer activities of foreign organizations.

- The term "real estate" shall comply with the provisions of Clause 2, Article 6 of the Double Taxation Avoidance Agreement between Vietnam and Ireland.

- The application of the Double Taxation Avoidance Agreement between Vietnam and Ireland for the Company's capital transfer activities in Ireland, the Company is requested to study the provisions in Article 14 of the Double Taxation Avoidance Agreement. times between Vietnam and Ireland and instructions in Article 27 of Circular 205/2013/TT-BTC mentioned above, compare with the actual situation arising to comply with regulations.