This transfer is explained by Vietnam’s General Department of Taxation, in an official letter issued to Big C Thang Long International Trade and Supermarket Service Company, as in essence a capital transfer between real estate companies in Vietnam and companies in the Big C Vietnam chain, covering capital, assets, real estate and commercial advantage, and gains from such transfer transparently originate from Vietnam, regardless of whether such transfer is carried out within or outside Vietnam, and therefore subject to corporate income tax. One of the shopping centers of the Big C Vietnam supermarket chain _ Photo: Internet French Casino Group and Thai Central Retail Corporation are believed to have wrongly interpreted the Vietnamese domestic law on corporate income tax regarding the taxation of capital gains from the transfer of Big C Vietnam supermarket chain.
