February 17, 2022 Vietnam signs Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS Executive summary On 9 February 2022, Vietnam signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (the MLI). At the time of signature, Vietnam submitted a list of 75 tax treaties entered into by Vietnam and other jurisdictions that Vietnam would like to designate as Covered Tax Agreements (CTAs), i.e., tax treaties to be amended through the MLI. Together with the list of CTAs, Vietnam also submitted a provisional list of reservations and notifications (MLI positions) in respect of the various provisions of the MLI. The definitive MLI positions will be provided upon the deposit of its instrument of ratification, acceptance or approval of the MLI. The key preliminary MLI positions include adopting the Principal Purpose Test and changes to the Mutual Agreement Procedure provisions, as part of the minimum standards, as well as non-mandatory provisions such as expanding the scope of permanent establishment rules and adopting a testing-period for real property threshold for source-country taxation of capital gains from alienation of shares/interests of entities. This Alert summarizes the key provisions in Vietnam's preliminary MLI positions. Detailed discussion Background On 5 October 2015, the Organisation for Economic Co-operation and Development (OECD) released its final report on developing a multilateral instrument to modify bilateral tax treaties under its Base Erosion and Profit Shifting (BEPS) Action Plan (Action 15). This report was released in a package that included final reports on all 15 BEPS Actions. On 24 November 2016, the OECD released the text of the MLI and explanatory notes.1 On 7 June 2017, 68 jurisdictions2 signed the MLI during a signing ceremony hosted by the OECD in Paris. Further, 31 additional jurisdictions (including Vietnam) have signed the MLI following the first ceremony. Together with the list of CTAs, signatories also submitted a preliminary list of their MLI positions in respect of the various provisions of the MLI. The definitive MLI positions for each jurisdiction will be/ have been provided upon the deposit of its instrument of ratification, acceptance or approval of the MLI. The MLI entered into force on 1 July 2018 after the first five jurisdictions (i.e., Austria, the Isle of Man, Jersey, Poland and Slovenia) deposited their respective instrument of ratification, acceptance or approval of the MLI with the OECD. Following this, to date, 68 additional jurisdictions have deposited their instrument of ratification, acceptance or approval of the MLI with the OECD. With respect to a specific bilateral tax treaty, the measures will only enter into effect after both parties to the treaty have deposited their respective instrument of ratification, acceptance or approval of the MLI and a specified time has passed. The specified time differs for different provisions. For example, for provisions relating to withholding taxes, the entry into force date is 1 January of the following year after the last party has notified of its ratification. Structure of the MLI Recognizing the complexity of designing a general instrument that applies to the CTAs and to the specific provisions included in bilateral tax treaties, the MLI provides flexibility for Contracting Jurisdictions to implement (parts of) the MLI based on their needs. Many of the provisions of the MLI overlap with provisions found in CTAs. Where the provisions of the MLI may conflict with existing provisions covering the same subject matter, this conflict is addressed through one or more compatibility clauses which may, for example, describe the existing provisions which the MLI is intended to supersede, as well as the effect on CTAs that do not contain a provision of the same type. Contracting Jurisdictions have the right to reserve certain parts of the MLI (opt-out) and to have these specific articles not apply to their tax treaties. The different types of provisions The MLI contains four types of provisions. Depending on the type of provision, the interaction with CTAs varies. A provision can have one of the following formulations: (i) "in place of"; (ii) "applies to"; (iii) "in the absence of"; and (iv) "in place of or in the absence of." A provision that applies "in place of" an existing provision is intended "to replace an existing provision" if one exists, and is not intended to apply if no existing provision exists. Parties shall include in their MLI positions a section on notifications wherein they will list all CTAs that contain a provision within the scope of the relevant MLI provision, indicating the article and paragraph number of each of such provision. A provision of the MLI that applies "in place of" shall replace a provision of a CTA only where all Contracting Jurisdictions have made a notification with respect to that provision. A provision that "applies to" provisions of a CTA is intended "to change the application of an existing provision without replacing it," and therefore may only apply if there is an existing provision. Parties shall include in their MLI positions a section on notifications wherein they will list all CTAs that contain a provision within the scope of the relevant MLI provision, indicating the article and paragraph number of each of such provision. A provision of the MLI that "applies to" provisions shall change the application of a provision of a CTA only where all Contracting Jurisdictions have made a notification with respect to that provision. A provision that applies "in the absence of" provisions of a CTA is intended "to add a provision" if one does not already exist. Parties shall include in their MLI positions a section on notifications wherein they will list all CTAs that do not contain a provision within the scope of the relevant MLI provision. A provision of the MLI that applies "in the absence of" provisions shall apply only in cases where all Contracting Jurisdictions notify the absence of an existing provision of the CTA. A provision that applies "in place of or in the absence of" provisions of a CTA is intended "to replace an existing provision or to add a provision." This type of provision will apply in all cases in which all the parties to a CTA have not reserved their right for the entirety of an article to apply to its CTAs. If all Contracting Jurisdictions notify the existence of an existing provision, that provision will be replaced by the provision of the MLI to the extent described in the relevant compatibility clause. Where the Contracting Jurisdictions do not notify the existence of a provision, the provision of the MLI will still apply. If there is a relevant existing provision which has not been notified by all Contracting Jurisdictions, the provision of the MLI will prevail over that existing provision, superseding it to the extent that it is incompatible with the relevant provision of the MLI (according to the explanatory statement of the MLI, an existing provision of a CTA is considered "incompatible" with a provision of the MLI if there is a conflict between the two provisions). Lastly, if there is no existing provision, the provision of the MLI will, in effect, be added to the CTA. Vietnam's CTAs and MLI provisions Vietnam has submitted a list of 75 tax treaties that it wishes to designate as CTAs, i.e., to be amended through the MLI. Accordingly, Vietnam has chosen to include the vast majority of the jurisdictions that form part of its tax treaty network. Some of the countries on Vietnam's CTA list, however, have not yet signed the MLI (for example, Brunei, Cambodia, and Venezuela). Also, Vietnam has not included five tax treaties in its network on its CTA list, i.e., the ones with Algeria, Macedonia, Egypt, the United States (all of which are not yet in force) and Taiwan. Hybrid mismatches Part II of the MLI (Articles 3 to 5) introduces provisions which aim to neutralize certain of the effects of hybrid mismatch arrangements based on the recommendations made in the BEPS Actions 2 and 6 final reports released in October 2015. The provisions cover hybrid mismatches related to transparent entities, dual resident entities and elimination of double taxation. These provisions are not minimum standard provisions and therefore Contracting Jurisdictions have the right to opt to not apply these provisions to their CTAs. Article 3 - Transparent entities This provision addresses the situation of hybrid mismatches as a result of entities that one or both Contracting Jurisdictions treat as wholly or partly transparent for tax purposes. Under Article 3(1), "for the purposes of a CTA, income derived by or through an entity that is treated as wholly or partly transparent under the tax law of either Contacting Jurisdiction shall only be considered income of a resident to the extent that the income is treated, for purposes of taxation by that Contracting Jurisdiction, as the income of a resident of that Contracting Jurisdiction." Article 3 of the MLI applies "in place of or in the absence of" an existing provision. Article 3 is not a provision required to meet a minimum standard and therefore jurisdictions can opt out of this article entirely. Vietnam has reserved the right for the entirety of Article 3 not to apply to its CTAs. Article 4 - Dual resident entities Article 4 modifies the rules for determining the treaty residency of a person other than an individual that is a resident of more than one Contracting Jurisdiction (dual resident entity). Under this provision, treaty residency of a dual resident entity shall be determined by a mutual agreement procedure (MAP) between Contracting Jurisdictions. Under the MAP in Article 4, Contracting Jurisdictions are not obligated to successfully reach an agreement and in absence of a successful mutual agreement, a dual resident entity is not entitled to any relief or exemption from tax provided by the CTA except as may be agreed upon by the Contracting Jurisdictions.Article 4 of the MLI applies "in place of or in the absence of" an existing provision. Article 4 is not a provision required to meet a minimum standard and therefore jurisdictions can opt out of this article entirely. Vietnam has reserved the right for the entirety of Article 4 not to apply to its CTAs. Article 5 – Application of methods for elimination of double taxation Article 5 includes three options for Contracting Jurisdictions for the methods of eliminating double taxation. Option A provides that provisions of a CTA that would otherwise exempt income derived or capital owned by a resident of a Contracting Jurisdiction would not apply where the other Contracting Jurisdiction applies the provisions of the CTA to exempt such income or capital from tax or to limit the rate at which such income or capital may be taxed (switch over clause). Instead, a deduction from tax is allowed subject to certain limitations. Under Option B, Contracting Jurisdictions would not apply the exemption method with respect to dividends if those dividends are deductible in the other Contracting Jurisdiction. Option C includes the provision that the "exemption method" is completely replaced with the "credit method." Contracting Jurisdictions may choose different options resulting in an asymmetrical application of this provision. Contracting Jurisdictions may also opt not to apply Article 5 to one or more of its CTAs. Article 5 of the MLI is not a provision required to meet a minimum standard and therefore jurisdictions can opt out of this option entirely. Vietnam has reserved the right for the entirety of Article 5 not to apply to its CTAs. Treaty abuse Part III of the MLI (Articles 6 to 13) contains six provisions related to the prevention of treaty abuse, which correspond to changes proposed in the BEPS Action 6 final report (Preventing the Granting of Treaty Benefits in Inappropriate Circumstances). In particular, the report contains provisions relating to the so-called "minimum standard" aimed at ensuring a minimum level of protection against treaty shopping (Article 6 and Article 7 of the MLI). Article 6 – Purpose of a CTA Article 6 contains the proposal described in the Action 6 final report to change the preamble language of a CTA to ensure compliance with one of the requirements of the minimum standard consisting of expressing the common intention to eliminate double taxation without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance, including through treaty shopping arrangements (Article 6(1)). Article 6 also includes optional wording that may be added to the preamble of a CTA referring to the desire to develop an economic relationship or to enhance cooperation in tax matters (Article 6(3)). Article 6 of the MLI applies "in place of or in the absence of" an existing provision. Article 6 is a provision required to meet a minimum standard and therefore jurisdictions cannot opt out of this article, unless they reserve the right for this article not to apply to its CTAs that already contain preamble language within the scope of the reservation. Vietnam has notified the list of agreements and the preamble language contained therein that would be replaced with the MLI preamble language in Article 6(1), if all Contracting Jurisdictions have made such notification (in other cases, the MLI preamble in Article 6(1) will be included in addition to the existing preamble language). Vietnam has also notified the list of agreements that do not contain the optional preamble language in Article 6(3) referring to a desire to develop an economic relationship or to enhance cooperation in tax matters. The optional preamble language will be included in the CTAs only where all Contracting States have chosen to apply Article 6(3) and have made such a notification with respect to the CTA. Article 7 – Prevention of Treaty Abuse This article contains the provisions to be included in a CTA to prevent treaty abuse. As concluded in the Action 6 final report, the prevention of treaty abuse should be addressed in one of the following ways: (i) a combined approach consisting of a Limitation on Benefits (LOB) provision and a principal purpose test (PPT); (ii) a PPT alone; or (iii) an LOB provision, supplemented by specific rules targeting conduit financing arrangements. With respect to the LOB provision, the Action 6 final report provided for the option of including a detailed or a simplified version. Given that a PPT is the only way that a Contracting Jurisdiction can satisfy the minimum standard on its own, it is presented as the default option in Article 7. Parties are allowed to supplement the PPT by electing to also apply a simplified LOB provision. Specifically, Article 7 articulates the PPT which denies treaty benefits when considering all relevant facts and circumstances, obtaining that benefit is one of the principal purposes for entering into a specific transaction or arrangement that resulted directly or indirectly in that benefit, unless if granting that benefit is not contrary to the object and purpose of the relevant provisions of the CTA. Vietnam has chosen to apply the PPT alone in addressing the prevention of treaty abuse. This election does not preclude any of the existing LOB provisions in its CTAs. Article 8 – Dividend transfer transactions Article 8 of the MLI specifies anti-abuse rules for benefits provided to dividend transfer transactions consisting of exempting or limiting the tax rate on dividends paid by a company resident of a Contracting Jurisdiction to a beneficial owner or recipient that is resident of the other Contracting Jurisdiction, provided certain ownership requirements which need to be met throughout a 365-day period that includes the day of payment of the dividend are met. The 365-day holding period will apply in place or in the absence of a minimum holding period contained in the provisions described above. Article 8 of the MLI applies "in place of or in the absence of" an existing provision. Article 8 is not a provision required to meet a minimum standard and therefore jurisdictions can opt out of this article entirely. Vietnam has reserved the right for the entirety of Article 8 not to apply to its CTAs. Article 9 – Capital gains from alienation of shares or interests of entities deriving their value principally from immovable property Article 9 incorporates an anti-abuse rule with respect to capital gains realized from the sale of shares of entities deriving their value principally from immovable property. In this respect, Article 9(1) provides two conditions to be incorporated into a CTA. Such conditions would require: (a) meeting a relevant value threshold (real property threshold) at any time during the 365 days preceding the sale; and (b) that the rule is expanded to apply to shares or comparable interests such as interests in a partnership or trust. The article provides that the 365-day period will replace or add such minimum period in CTAs, unless a Party wishes to preserve the minimum period specified in its CTAs. In addition, Article 9(4) allows Parties to apply Article 13(4) of the OECD Model Tax Convention as included in the Action 6 final report that provides a 365-day holding period prior to the alienation of shares, and requires that the shares or comparable interests derive more than 50% of their value directly or indirectly from immovable property. Article 9 of the MLI contains two substantial provisions (Article 9(1) and Article 9(4) which is an optional addition) and both apply "in place of or in the absence of" an existing provision. Article 9 is not a provision required to meet a minimum standard and therefore jurisdictions can opt out of this article entirely. Vietnam has reserved the right for Article 9(1)(b) (i.e., expanded scope covering comparable interests such as interests in a partnership or trust) not to apply to its CTAs. Vietnam has notified the list of CTAs that contains a provision described in Article 9(1) and the article and paragraph number of each such provision. Vietnam has also chosen to apply Article 9(4) but reserved the right for Article 9(4) not to apply to its CTAs that already contain a real property threshold. Article 9(4) is an optional provision and will apply to a CTA only where all Contracting Jurisdictions have chosen to apply it by making a notification to that effect. Accordingly, in a CTA which does not already have a real property threshold provision and where the other Contracting Jurisdiction has also opted for Article 9(4), the 365-day testing period and 50% real property threshold under Article 9(4) would apply for capital gains on alienation of shares or comparable interests under such CTA. In the case of CTAs where Article 9(4) does not apply, Article 9(1)(a) would apply if all Contracting Jurisdictions have opted for such provision and, accordingly, the 365-day testing period would replace any existing testing periods or is added where such testing periods do not exist in the CTAs. Article 10 – Anti-abuse rule for permanent establishments situated in third jurisdictions Article 10 contains the anti-abuse rule for permanent establishments (PEs) situated in third jurisdictions, the so-called "triangular provision." The article provides that treaty benefits will be denied if an item of income derived by a treaty resident and attributable to a PE in a third jurisdiction, is exempt from tax in the residence state and the tax in the PE jurisdiction is less than 60% of the tax that would be imposed in the residence state if the PE were located there. The article makes an exception for cases where the income is derived in connection to or incidental to an active trade or business carried out through the PE, and allows discretionary relief to be requested when treaty benefits are denied under this article. Article 10 of the MLI applies "in place of or in the absence of" an existing provision. Article 10 is not a provision required to meet a minimum standard and therefore jurisdictions can opt out of this article entirely. Vietnam has reserved the right for the entirety of Article 10 not to apply to its CTAs. Article 11- Application of tax agreements to restrict a party's right to tax its own residents Article 11 contains a so-called "saving clause" rule that preserves a Party's right to tax its own residents. Article 11 of the MLI applies "in place of or in the absence of" an existing provision. Article 11 is not a provision required to meet a minimum standard and therefore jurisdictions can opt out of this article entirely. Vietnam has reserved the right for the entirety of Article 11 not to apply to its CTAs. Avoidance of PE status Part IV of the MLI (Articles 12 to 15) describes the mechanism by which the PE definition in existing tax treaties may be amended pursuant to the BEPS Action 7 final report to prevent the artificial avoidance of PE status through: (i) commissionaire arrangements and similar strategies (Article 12); (ii) the specific activity exemptions (Article 13); and (iii) the splitting-up of contracts (Article 14). Article 15 of the MLI provides the definition of the term "closely related to an enterprise," which is used in Articles 12 through 14. Article 12 - Artificial avoidance of PE status thought commissionaire arrangements and similar strategies This article sets out how the changes to the wording of Article 5 of the OECD Model Tax Convention to address the artificial avoidance of PE status through commissionaire arrangements and similar strategies can be incorporated in the CTAs specified by the parties. In particular:
Article 12 of the MLI applies "in place of" an existing provision. This article is intended to replace an existing provision if one exists, and is not intended to apply if an existing provision does not exist. Article 12 of the MLI will apply only in cases where all Contracting Jurisdictions (i.e., parties to a CTA under the MLI) make a notification with respect to the existing provision of the CTA. Article 12 has two notification clauses. One for the definition of dependent agent and another for definition of independent agent. Further, Article 12 is not a provision required to meet a minimum standard and therefore jurisdictions can opt out of this article entirely. Vietnam has chosen to apply Article 12 to its CTAs. Therefore, Article 12(1) and Article 12(2) of the MLI could apply provided that all Contracting Jurisdictions have made a notification in such respect. Article 13 – Artificial avoidance of PE status through the specific activity exemptions This article addresses the artificial avoidance of PE status through the specific activity exemptions included in Article 5(4) of the OECD Model Tax Convention. Action 7 recommended that this exemption should only be available if the specific activity listed is of a preparatory or auxiliary character. The MLI provides two options for implementing the changes. Option A is based on the proposed wording in Action 7 (i.e., this exemption should only be available if the specific activity listed is of a preparatory or auxiliary character), while Option B allows the Contracting Jurisdiction to preserve the existing exemption for certain specified activities. This article applies "in place of" an existing provision and therefore this first part of this article is intended to replace an existing provision if one exists, and is not intended to apply if an existing provision does not exist. Vietnam has chosen to apply Option A. Article 13(4) contains a second substantial provision: the anti-fragmentation clause, pursuant to which exemptions included in Article 5(4) of the OECD Model Tax Convention will not apply in situations where the business activities may constitute complementary functions that are part of a cohesive business operation. Article 13(4) "applies to" provisions of a CTA. This type of provision is intended to change the application of an existing provision without replacing it, and therefore can only apply if there is an existing provision. For this reason, the notification provision of Article 13 states that the provision of the Convention will apply only in cases where all Contracting Jurisdictions make a notification with respect to the existing provision of the CTA. The anti-fragmentation clause is not a provision required to meet a minimum standard and therefore jurisdictions can opt out of this option entirely. Vietnam has chosen to apply Article 13(4) and thus the anti-fragmentation clause will apply provided that all Contracting Jurisdictions have made a notification in such respect. Article 14 – Splitting-up of contracts Under the Action 7 final report recommendations on "Preventing the Artificial Avoidance of PE Status" the splitting-up of contracts is a potential strategy for the avoidance of PE status through abuse of the exception in Article 5(3) of the OECD Model Tax Convention, governing the situations where building sites, construction or installation projects may constitute a PE. The Action 7 final report further noted, however, that the PPT provision could still address BEPS concerns related to the abusive splitting-up of contracts in these types of cases. Article 14 of the MLI applies "in place of or in the absence of" an existing provision. Article 14 is not a provision required to meet a minimum standard and therefore jurisdictions can opt out of this article entirely. Vietnam has reserved the right for the entirety of Article 14 not to apply to its CTAs. Article 15 – Definition of a person closely related to an enterprise Article 15 describes the conditions under which a person will be considered to be "closely related" to an enterprise for the purposes of Articles 12, 13 and 14 of the MLI. Therefore, only jurisdictions that have made the reservations under Article 12(4), Article 13(6)(a), Article 13(6)(c) and Article 14(3)(a), may reserve their right for the entirety of Article 15 to not apply. Vietnam has chosen to apply Article 15. Improving dispute resolution Part V of the MLI (Articles 16 and 17) introduces provisions which aim to introduce the minimum standard for improving dispute resolution (the BEPS Action 14 minimum standards) and a number of complementing best practices. Article 16 – MAP Article 16 of the MLI requires countries to include in their tax treaties the provisions regarding the MAP of Article 25 paragraph 1 through paragraph 3 of the OECD Model Tax Convention, including certain modifications of those provisions. The first sentence of Article 16(1) allows a taxpayer to present a case to the competent authority of either Contracting Jurisdiction irrespective of the remedies available under the domestic law, while Article 16(2) stipulates a timeline for presenting the case, i.e., three years from the first notification of the action resulting in taxation not in accordance with the provisions of the CTA. Vietnam reserves the right for the first sentence of Article 16(1) not to apply to its CTAs on the basis that it intends to meet the minimum standard for improving dispute resolution under the OECD/G20 BEPS Package. Broadly, such minimum standards are met by ensuring that under each of its CTAs (other than a CTA that already permits presenting a case to the competent authority of either Contracting Jurisdiction), the taxpayer may present the case to the competent authority of the Contracting Jurisdiction where the taxpayer is resident, and such competent authority will implement a bilateral notification or consultation process with the competent authority of the other Contracting Jurisdiction. As Vietnam has not made any reservations with respect to any other paragraphs/provisions in Article 16, the relevant notifications required for such applicable provisions have been made. For instance, with respect to the second sentence of Article 16(1) (i.e., three-year timeline), Vietnam has notified the list of CTAs that contain a provision that provides for a timeline that is shorter than three years as well as those that provide for a timeline that is at least three years from the first notification of the action resulting in taxation not in accordance with the provisions of the CTA. Similarly, with respect to the second sentence of Article 16(2) which provides that any agreement reached under MAP shall be implemented irrespective of any time limits in the domestic laws of the Contracting Jurisdictions, Vietnam has notified the list of agreements that does not contain such a provision. Vietnam has not notified any treaties which do not have an existing provision comparable to the first sentence of Article 16(2) which provides for mutual agreement by the competent authorities with a view to the avoidance of taxation which is not in accordance with the CTA. Article 17 – Corresponding adjustments This provision is meant to apply in the absence of provisions in CTAs that require a corresponding adjustment where the other treaty party makes a transfer pricing adjustment. Article 17 of the MLI applies "in place of or in the absence of" an existing provision. Article 17 is not a provision required to meet a minimum standard and therefore jurisdictions can opt out of this article entirely. However, the BEPS Action 14 minimum standard requires that jurisdictions provide access to the MAP in transfer pricing cases and implement the resulting mutual agreements regardless of whether the tax treaty contains a provision dealing with corresponding adjustments. In light of this, a Party may reserve the right not to apply Article 17 of the MLI on the basis that in the absence of a corresponding adjustments provision, either: (i) the Party making the reservation will make the corresponding adjustment as described in Article 17 of the MLI; or (ii) its competent authority will endeavor to resolve a transfer pricing case under the MAP provision of its tax treaty. Where one Contracting Jurisdiction to a CTA makes such a reservation and the other Contracting Jurisdiction does not, Article 17 of the MLI will not apply to the CTA, and there is no expectation created under the MLI that the Contracting Jurisdiction that has not made the reservation will make a corresponding adjustment. A Party may also reserve the right for Article 17 not to apply to its CTAs that already contain a corresponding adjustment provision of the same type as that provided in Article 17(2). Vietnam has reserved the right for the entirety of Article 17 not to apply to its CTAs. Mandatory binding arbitration Part VI of the MLI (Articles 18 to 26) enables countries to include mandatory binding treaty arbitration (MBTA) in their CTAs in accordance with the special procedures provided by the MLI. Unlike the other Articles of the MLI, Part VI applies only between jurisdictions that expressly choose to apply Part VI with respect to their tax treaties. As of 9 February 2022, of the 99 jurisdictions that signed the MLI, 33 have opted in for MBTA.3 Vietnam at the moment has not opted in for MBTA. Implications The signing of the MLI is part of the Vietnamese Government's recently-approved plan to align its tax treaty network with international practices and developments.4 Vietnam intends to apply MLI provisions to 75 tax treaties, i.e., the vast majority of those which make up its tax treaty network. Most of the treaties not included as a CTA are those that are not yet in force. This certainly constitutes an unprecedented moment for Vietnam's international taxation and the implementation of the treaty-based BEPS recommendations. The provisional reservations and notifications made by Vietnam at the MLI signature seem quite balanced and consistent with the double tax treaty negotiation policies followed by Vietnam during the past years. _________________________________________ For additional information with respect to this Alert, please contact the following: EY Consulting Vietnam JSC
Ernst & Young LLP (United States), Vietnam Tax Desk, New York
Ernst & Young LLP (United States), Asia Pacific Business Group, New York
Ernst & Young LLP (United States), Asia Pacific Business Group, Chicago
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