China – Vietnam Tax Treaty
The China-Vietnam tax treaty caps withholding on dividends at 10%, and interest at 10%. Royalties are taxed at a uniform 10% across all categories. Private pensions are taxable only in the country of residence, with no withholding at source. This is one of 47 active treaties in China's network and one of 26 in Vietnam's. The general dividend rate of 10% compares to a median of 10% across China's network and 15% across Vietnam's.
Verified data
GDT Tax Treaty Network (gdt.gov.vn) (Treaty list verified April 2026. Rates from individual treaty texts (Articles 10-12). Vietnam has 0% domestic WHT on dividends paid to non-resident shareholders.)
Withholding Rate Summary
Source: Vietnam Treaty Reference| Income Type | Treaty Rate | Statutory Rate (Vietnam) |
|---|---|---|
| Dividends (general) Portfolio investors | 10% | 0% |
| Dividends (qualified) Beneficial owner is a company holding >= 10% of voting stock | 10% | 0% |
| Interest Bank interest, bonds, loans | 10% | 5% |
| Royalties (avg) Patents, copyright, know-how, film/TV | 10% | — |
| Pensions Private pension distributions | 0% | — |
| Social Security Government social security benefits | 0% | — |
“Treaty Rate” is the maximum withholding permitted under this treaty. The actual effective rate may be lower if domestic law provides a more favorable rate independently. “Statutory Rate (Vietnam)” shows the rate that applies when no treaty benefit is claimed. Qualified dividend rate requires: Beneficial owner is a company holding >= 10% of voting stock.
Dividends
The general dividend rate of 10% applies to portfolio investors. A reduced rate of 10% is available when beneficial owner is a company holding >= 10% of voting stock. Without the treaty, the statutory withholding rate on dividends is 0%.
Source: Vietnam Treaty Reference
Interest
Interest payments (bank interest, bonds, loans) are subject to 10% withholding under this treaty, compared to the 5% statutory rate. This represents a no reduction from the statutory rate.
Source: Vietnam Treaty Reference
Royalties
Royalty withholding rates vary by the type of intellectual property. This treaty distinguishes 4 categories, with rates ranging from 10% to 10%.
Source: Vietnam Treaty Reference
Pensions & Social Security
Private pension distributions are taxable only in the country of residence, with no withholding at source. Government social security benefits are exempt from source-country withholding.
Source: Vietnam Treaty Reference
Comparative Context
🇨🇳China's Network
Among China's 47 active treaty partners, the 10% general dividend rate ranks 38th (median: 10%).
| Partner | Rate |
|---|---|
| Slovak Republic | 10% |
| Turkey | 10% |
| United States | 10% |
| Vietnam (this treaty) | 10% |
| South Africa | 10% |
| Australia | 15% |
| Brazil | 15% |
🇻🇳Vietnam's Network
Among Vietnam's 26 active treaty partners, the 10% general dividend rate ranks 3rd (median: 15%).
| Partner | Rate |
|---|---|
| Malaysia | 0% |
| Switzerland | 10% |
| China (this treaty) | 10% |
| Hong Kong | 10% |
| India | 10% |
| Japan | 10% |