Scenario: a Korean group has subsidiaries in Vietnam, Korea and Taiwan — all profitable. Headquarters wants one dividend sweep. How much tax does each source “lose” on the way home?
Vietnam source: 0% — the cheapest source
Dividends from a Vietnamese company to a Korean/Taiwanese corporate parent: 0% withholding in Vietnam. No treaty file needed. Procedure: dividend resolution + audited financial statements + completed tax finalization → ICA transfer (Circular 38/2026/TT-NHNN (replacing Circular 06/2019/TT-NHNN, which ceased to have effect on 18 August 2026), Circular 186/2010/TT-BTC). The new circular’s account-opening scope also covers foreign-invested economic organisations established before an Investment Registration Certificate is issued. Of the three sources, Vietnam is the cheapest and simplest on tax.
Korea source: 22% domestic, 10% under treaty
Dividends from a Korean company to a foreign parent: Korea withholds 22% domestically (20% + 2% local surtax, commonly published) — the highest of the three. The Vietnam–Korea DTA (1994), Article 10, cuts the cap to 10% (commonly published) — but only if the Vietnamese parent (as recipient) proves Vietnamese tax residence and beneficial ownership, filing with the Korean payer. If the ultimate parent sits in a third country (not Vietnam): Korea’s DTA with that country applies — check each pair.
Taiwan source: 21% domestic, ~10% under the 1998 treaty
Dividends from a Taiwanese company to a foreign parent: 21% domestic withholding (commonly published). The Vietnam–Taiwan treaty (1998), Article 10, brings it to the commonly published 10% — conditional on residence and beneficial-ownership proof. Plus the capital-remittance approval layer (MOEAIC/CBC) analyzed earlier. Cost ranking: Vietnam (0%) → Taiwan (~10% treaty) → Korea (10% treaty, 22% without).
Bottom line for decision-makers
The optimal sweep calendar: pull from Vietnam first (0%, clean procedure — just hit the audit/finalization schedule); for Korean/Taiwanese sources, prepare treaty files from the year’s start (COR + beneficial ownership) for 10% instead of 22%/21%. Reinvesting in Vietnam vs repatriating: Vietnam offers no special tax incentive for reinvestment over repatriation (0% either way at the dividend stage) — decide on real business capital needs, not tax. The rule: cheap money first, expensive money well-prepared.
Frequently Asked Questions
What tax on dividends from Vietnam to Korean/Taiwanese parents?
0% Vietnamese withholding (corporate shareholders). No treaty file; ICA transfer after audit and tax finalization.
What tax on dividends from Korea?
22% domestic (20% + 2% surtax, commonly published); 10% with a successful Article 10 Vietnam–Korea DTA claim (COR + beneficial ownership required).
What tax on dividends from Taiwan?
21% domestic (commonly published); about 10% under Article 10 of the 1998 treaty (residence + beneficial-ownership proof); plus the MOEAIC/CBC remittance layer.
Reinvest in Vietnam or repatriate?
Tax-neutral at the dividend stage (0%); decide on real business capital needs. Sweep calendar: Vietnam source (cheap, clean) first.
This article has been quality-reviewed by the FLAW AI Legal Council
