제19906호                               관               보                   2020. 12. 28.(월요일)
                                     EXCHANGE OF NOTES
                BETWEEN THE GOVERNMENT OF THE REPUBLIC OF KOREA
       AND THE GOVERNMENT OF THE SOCIALIST REPUBLIC OF VIET NAM
      CONCERNING THE AMENDMENT OF THE FRAMEWORK ARRANGEMENT
 CONCERING LOANS FROM THE ECONOMIC DEVELOPMENT COOPERATION FUND
                             FOR THE YEARS 2016 THROUGH 2020
                                     (Korean Proposing Note)
                                                                              Hanoi, 15 December, 2020
Excellency,
I have the honor to refer to the Framework Arrangement between the Government of the
Republic of Korea and the Government of the Socialist Republic of Viet Nam concerning Loans
from the Economic Development Cooperation Fund for the Years 2016 through 2020, signed at
Hanoi on November 8, 2017 (hereinafter referred to as the "Arrangement").


In accordance with Article 8 of the Arrangement, I have also the honor to propose, on behalf of
the Government of the Republic of Korea, that the phrase “the years 2016 through 2020” in the
title of the Arrangement be replaced by the phrase “the years 2016 through 2023” and that the
existing Article 1 and Article 3.1 (h) of the Arrangement be replaced by the following:
    Article 1:
    “The Korean Government shall enable the Vietnamese Government to obtain loans from the
    Economic Development Cooperation Fund (hereinafter referred to as the “EDCF”) up to a
    maximum commitment amount in Korean Won not exceeding the equivalent of one billion five
    hundred million US dollars (US$ 1,500,000,000) for the years 2016 through 2023 to finance
    EDCF loan projects in the Socialist Republic of Viet Nam, unless otherwise agreed by the
    Parties.”
    Article 3.1 (h):
    “The      Vietnamese   Government shall   ensure   that   import   tax,   special consumption   tax,
    environment protection tax and value added tax imposed in the Socialist Republic of Viet
    Nam with respect to the purchase of materials, equipment and services for the project, which
    are procured or authorized to be procured by the Vietnamese executing agencies and which
    duly constitute the value of the project, be borne by the said agencies. In other cases,
    including the purchase of materials, equipment and services, procured by the suppliers for the
    project, which do not duly constitute the value of the project, the suppliers and other related
    organizations and individuals must comply with the laws and regulations of the Socialist
    Republic of Viet Nam on taxation. The suppliers of the project are obliged to pay corporate
    income tax and personal income tax in accordance with the laws of the Socialist Republic of
    Viet Nam, and in accordance with the provisions of the Agreement between the Government
    of the Republic of Korea and the Government of the Socialist Republic of Viet Nam for the
    Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on
    income.”
If this proposal is acceptable to the Government of the Socialist Republic of Viet Nam, I have the
further honor to propose that this Note and Your Excellency's Note in Reply shall constitute an

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