Vietnam–SwedenDouble Tax Agreement
Features a low 5% royalties rate, benefiting Swedish technology and manufacturing companies like Ericsson, Volvo, and Ikea with IP-based income from Vietnam.
Important notice. Treaty rates shown are standard rates from published treaty texts. Reduced rates may apply subject to beneficial ownership requirements and other conditions specified in each treaty article. Tax treaty application is technically complex and fact-specific. Consult a qualified tax advisor for your specific situation before relying on these rates.
Withholding Tax Rates at a Glance
Dividends WHT
10%on dividend payments
Interest WHT
10%on interest payments
Royalties WHT
5%on royalty payments
Treaty Signed
1994
In Force Since
1995
Status
Active
Model
OECD-based
What This Means for Expats
Residency Tie-Breaker Rules
Residency tiebreaker: permanent home, vital interests, habitual abode, then nationality.
Practical Context
Sweden has a DTA with Vietnam that is particularly favorable for technology-intensive businesses due to the 5% royalties rate. Swedish companies have a significant presence in Vietnam's telecoms, furniture, and manufacturing sectors. Swedish expats on long-term assignments to Vietnam should seek advice on Swedish exit tax rules and treaty residency.
Key Treaty Provisions Explained
Dividends
10% capWhen a Vietnamese company pays dividends to a Sweden shareholder, Vietnam withholds 10% under this treaty — compared to Vietnam's standard domestic rate which may be higher. This applies to portfolio investors. Substantial shareholders may qualify for even lower rates in some treaties.
Interest
10% capInterest paid by a Vietnamese borrower to a Sweden lender is subject to a maximum 10% withholding tax under this treaty. This is relevant for intercompany loans between Sweden parent companies and Vietnamese subsidiaries, as well as bonds and other debt instruments.
Royalties
5% capRoyalties paid from Vietnam to Sweden for use of IP (patents, trademarks, software, know-how) are capped at 5% withholding tax. This is a favorable rate compared to many other treaties — particularly advantageous for Sweden companies licensing technology to Vietnamese operations.
Frequently Asked Questions
Does Vietnam have a tax treaty with Sweden?
Yes. Vietnam and Sweden have a Double Taxation Agreement (DTA) that has been in force since 1995. The treaty prevents the same income from being taxed in both countries and sets withholding tax caps on dividends, interest, and royalties.
What is the withholding tax rate on dividends under the Vietnam–Sweden DTA?
Under the Vietnam–Sweden DTA, the withholding tax on dividends is capped at 10%. Without a treaty, Vietnam's standard domestic WHT rate on dividends paid to foreign entities is generally higher. Always confirm the applicable rate with a tax adviser, as lower rates may apply if specific shareholding thresholds are met.
How does the Sweden–Vietnam DTA affect my salary as an expat?
Under Article 15 of the Vietnam–Sweden DTA, employment income is generally taxable in Vietnam if you are working in Vietnam. The treaty's tiebreaker rules determine your residency: Residency tiebreaker: permanent home, vital interests, habitual abode, then nationality. If you are a Vietnamese tax resident, your worldwide income may be subject to Vietnam PIT, with a credit or exemption for taxes paid in Sweden.
What is a Permanent Establishment (PE) under the Vietnam–Sweden treaty?
A Permanent Establishment is a fixed place of business through which a Sweden company carries on business in Vietnam. If a PE exists, Vietnam can tax the profits attributable to it. Common PE triggers include offices, branches, factories, construction sites lasting more than 6 months, and dependent agents. Sweden companies operating in Vietnam should assess PE risk carefully.
Get Tax Advice for Vietnam
Whether you need help with Vietnam PIT filing, applying treaty benefits, or cross-border tax planning, our team is here to help.