5 Nov 2026 · Vietnam VI

Citizenship · Capital · Global Mobility

The Legation Times

No Greece–Vietnam tax treaty appears on either country’s official list

Edward Nguyen Edward Nguyen
A woman's hands hold a fan of 100-euro banknotes at a desk, beside a sheet of paper marked Finance, a phone showing a calculator and an open notebook with a pen

Treaties with Portugal, Spain, Malta, Italy, Hungary and Latvia let Vietnam credit tax paid on a home there; Vietnam's decree ties the credit to a signed treaty.

A Vietnamese tax resident with a home in Portugal, Spain, Malta, Italy, Hungary or Latvia is covered by a double tax agreement under which Vietnam credits tax paid there, up to the Vietnamese tax on that income. The official lists read on 15 October 2026 show no such agreement for Greece. Cyprus signed one in December 2025, and the 2015 agreement with the United States is not shown in force.

Why a treaty matters to a resident of Vietnam

Vietnam taxes its residents on taxable income “arising inside and outside” its territory, under the Personal Income Tax Law No. 109/2025/QH15, in force since 1 July 2026. This means that income from a home abroad can fall within the tax of both Vietnam and the country where the home stands.

No clause on foreign tax credit was found in the law itself. Decree 253/2026/NĐ-CP, in force the same day, provides one in article 6(3): for countries with which Vietnam “has signed” a double tax agreement, income tax paid abroad is deducted from the tax payable in Vietnam “according to the Agreement”.

The decree text read provides no express credit for tax paid in a country with no signed agreement. This indicates that, on the texts read, the same income from such a country may be taxed twice.

Six treaties in force

Country Signed In force Covers Vietnamese tax from
Portugal 3 June 2015 9 November 2016 2017
Spain 7 March 2005 22 December 2005 2006
Malta 15 July 2016 25 November 2016 2017
Italy 26 November 1996 20 February 1999 1996, retroactively
Hungary 26 August 1994 30 June 1995 1996
Latvia 19 October 2017 6 August 2018 2019

Each year in the table is read from the treaty’s entry-into-force article. For five of the treaties it is 1 January of the year after entry into force; Italy’s article applies to periods beginning on or after 1 January 1996, before the treaty entered into force.

Signing and in-force dates come from the General Department of Taxation’s treaty list, the Ministry of Foreign Affairs treaty database and the partner’s own gazette.

What the treaties say about a home

All six follow the same structure. Income from immovable property, such as rent, “may be taxed” in the country where the property is situated, under article 6. Gains on selling it may also be taxed there, under article 13, or article 14 in the Maltese treaty.

Vietnam’s side is a credit. In the treaty with Portugal, Vietnam allows “as a credit against its tax on the income an amount equal to the tax paid in Portugal”, capped at the Vietnamese tax on that income. The Spanish, Italian and Hungarian treaties use the same structure.

The Maltese treaty calls it a “deduction” from Vietnamese tax and words the cap differently: it says “the lesser of” but names one figure only, the tax that would have been charged on the same income in Vietnam.

The Latvian treaty speaks of a reduction. On the texts read, the structure is the same in all six: tax paid abroad comes off the Vietnamese bill, up to the Vietnamese tax on that income.

None of the six treaties lists an inheritance, estate or gift tax among the taxes it covers. All six do cover Vietnam’s personal income tax, and the Vietnamese law lists income from inherited or gifted real estate among taxable income.

Greece does not appear on the lists read

The General Department of Taxation’s treaty list, last updated on 4 June 2019, includes Portugal and Spain but not Greece. The Greek tax authority’s list of treaty texts, read on 15 October 2026, has 58 numbered partner countries, among them Cyprus and Portugal, and Vietnam is not one of them.

A search of Vietnam’s Ministry of Foreign Affairs treaty database the same day returned six agreements with Greece, covering visas, air transport, investment protection, culture, tourism and economic cooperation. None concerns tax. The same database holds the tax agreement with Cyprus.

Cyprus and the United States

Cyprus and Vietnam signed a double tax agreement on 15 December 2025. Vietnam’s Ministry of Foreign Affairs records it in force from 10 April 2026; the Cypriot finance ministry’s table, modified on 8 October 2026, leaves the entry-into-force column blank for Vietnam.

The agreement with the United States was signed on 7 July 2015 and approved by Vietnam’s government in February 2017. The General Department of Taxation’s list, updated on 4 June 2019, shows it as not effective, and the Internal Revenue Service’s list of treaties in force, last reviewed on 3 January 2026, does not include Vietnam.

Spain and Portugal no longer take new property applicants

Spain closed its investor residence routes to new applicants from 3 April 2025, and Portugal stopped accepting new applications on its property routes from 7 October 2023.

In the Portuguese and Spanish treaties, article 6(1) and article 13(1) turn on the owner’s tax residence and on where the property stands, not on a residence permit.

What this article has not established

The text of the Cyprus treaty, its articles on property and credit, and the year from which it applies were not read.

The Spanish gazette’s page for the Spain treaty notes that the OECD multilateral instrument of 24 November 2016 may have affected it. Whether the instrument modifies any of the six treaties was not checked.

For Italy and Hungary, the text read is the tax department’s English version, not the authentic gazette text; for Latvia, the Latvian text was read, though the English text prevails.

How the decree’s “has signed” wording applies to an agreement signed but not in force, such as the one with the United States, was not established. The circulars implementing the decree were not read.

How Vietnam computes tax on a resident’s sale of a home abroad, how it classifies foreign rental income and the procedure for claiming a credit were not established. How a treaty would treat Vietnam’s tax on an inherited home abroad was not examined.

The search of the Ministry of Foreign Affairs database is not exhaustive: it did not return every agreement that the tax department’s list shows in force.

Three Greek Parliament files whose names refer to Vietnam could not be opened, and their subject was not established.

The rules that decide who counts as a Vietnamese tax resident were not examined here; they are covered in an explainer on tax residence.

The Legation Times writes its content from published documents; nothing here is legal, tax or investment advice. Spotted an error? Send a correction request; for content rights, send a takedown request.

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