On June 17, 2025, Cambodia’s Ministry of Economy and Finance issued Instruction No. 18574 on Tax Obligations for Share Premiums to clarify that enterprises are not required to pay any income tax on share premiums that meet the conditions set out in the instruction. As outlined in the relevant provisions of the Law on Taxation (Royal Kram No. NS/RKM/0523/004) and Prakas No. 578 MEF.PrK.GDT on Tax on Income, taxable income is the difference between an asset’s value at the beginning and end of a period. This calculation deducts capital contributions, which are not taxable. A share premium is the amount of money that a company receives in excess of the par value of a share when the company issues new shares to a shareholder through a share subscription. In other words, share premiums are capital contributions made by shareholders into the equity of the company and, as a result, are not taxable. However, the government may nevertheless view share premiums as taxable if the company fails to meet certain legal conditions. Cambodian law requires share subscriptions to be properly recorded in the company’s accounting books and supported by documentary evidence. The recent instruction states that if an enterprise does not have proper documentation, any increase in equity, such as a capital increase through share premiums, will be treated as taxable income in accordance with the law. The instruction provides the following example: Enterprise A issues 200,000 new shares to an investor. The shares were registered with a par value of KHR 4,000 per share and were sold for a sale price of KHR 10,000 per share. The share premium of KHR 1.2 billion, which is calculated by subtracting the total par value (KHR 800 million) from the total value of the new capital (KHR 2 billion), is a capital

As of July 1, 2025, all companies in Vietnam have new addresses. The country’s administrative map has been redrawn and relabeled as part of an ambitious government restructuring, and every address in the country has been modified to at least a small degree due to provinces merging, the district level of local government being eliminated, and the surviving administrative divisions being reconfigured and renamed. Companies operating in Vietnam should note the guidance below regarding their obligations. Business Registration Guidance issued by Vietnam’s Ministry of Finance under Official Letter No. 4370/BTC-DNTN dated April 5, 2025, regarding business registration in the event of changes to administrative boundaries, provides the following principles: Enterprises may continue to use their existing Enterprise Registration Certificates even when administrative boundaries have changed. There is no requirement to register a change of address solely due to these changes. Enterprises may choose to update their registered addresses either when submitting applications for other business registration changes or at their own discretion. Tax-Related Matters The Tax Department of the Ministry of Finance and Regional Tax Sub-Departments have further issued the following guidance on tax-related matters: The tax authorities will issue notifications regarding the update of taxpayers’ addresses according to the new administrative boundaries. These notifications will also include information on the directly managing tax authority. The notifications will be communicated via the taxpayer’s electronic tax transaction account, or the taxpayer’s email address through the legal representative’s eTax Mobile application. These notifications will serve as a basis for taxpayers to explain to relevant authorities or clarify to customers in cases where the address shown on the invoice is the address updated by the tax authority according to the new administrative boundaries, but the information on the Enterprise Registration Certificate still shows the address according to the old administrative boundaries. Summary

Vietnam is making notable strides in decentralization, aiming to grant greater autonomy to local government entities to streamline administrative procedures. As part of this effort, the government issued Decree No. 133/2025/ND-CP on decentralization of state management of the Ministry of Science and Technology dated June 12, 2025 (Decree 133). Effective from July 1, 2025, Decree 133 decentralizes and delegates numerous state management functions—including in intellectual property (IP) and technology transfer—to provincial-level People’s Committees (PCs). This reform signals a profound shift in how IP rights are administered and enforced across Vietnam. While this offers new opportunities for IP owners, agents, and innovators, it also introduces additional operational complexities. Impact on IP and Technology Transfer Decree 133 significantly reallocates responsibilities in IP and technology transfer, primarily to provincial-level PCs. Provincial PCs and other provincial authorities are now empowered to handle a wide range of tasks, including but not limited to the following: Issuance of duplicates and reissuance of certificates of registration. Registration of license agreements for the transfer of usage rights for industrial property objects (e.g., trademarks, patents) and recording amendments, extensions, or early terminations of such agreements. Enforcing decisions on compulsory licensing of patent use rights. Evaluation and approval of technology transfer contracts—a key step in facilitating localized technological advancements. Permitting the establishment of foreign-invested scientific organizations and their branches, to encourage foreign direct investment in local R&D and technology development. Approval of provincial-level R&D tasks, aligning with local socio-economic development priorities. Legal Implications The decentralization and delegation brought forth by Decree 133 carry several significant legal implications: Echoing Decree 133, the Intellectual Property Office of Vietnam issued Notification No. 2351/TB-SHTT on June 26, 2025, announcing the cessation of 19 administrative procedures at the national level. Specifically, from July 1, 2025, the IP Office will no longer accept requests related

On April 29, 2025, the State Bank of Vietnam (SBV) issued Circular No. 03/2025/TT-NHNN (Circular 03), which provides detailed guidance on the opening and use of Vietnamese dong (VND) accounts by non-resident foreign investors engaging in indirect investment activities in Vietnam. Circular 03, which took effect on June 16, 2025, amends Circular No. 06/2019/TT-NHNN of the SBV on the management of foreign exchange for foreign direct investment activities in Vietnam (Circular 06) and replaces Circular No. 05/2014/TT-NHNN of the SBV guiding the opening and use of indirect investment capital accounts for implementation of foreign indirect investment activities in Vietnam (Circular 05). Below are some of the key points of Circular 03. Change of Account Name Circular 03 renames “indirect investment capital account” to “indirect investment account” (IIA). This change aligns with the terminology used in other legislation, ensuring consistency across Vietnam’s legal framework governing foreign exchange and investment activities. Additionally, by removing the word “capital,” the new term better encompasses the full range of transactions that may be conducted through these accounts, such as share transfer and other forms of indirect investment-related activities. This helps prevent misinterpretation and facilitates compliance for foreign investors operating in Vietnam. Account Types Circular 03 clearly delineates account types and investor residency status as follows: For non-resident foreign investors: The opening and use of investment accounts in VND is for carrying out transactions related to indirect investment activities. For resident foreign investors: Credit and debit transactions are made through payment accounts in VND in accordance with relevant laws. Additional Permitted Uses of IIAs In addition to the cash inflows and outflows authorized under Circular 05, Circular 03 introduces more cash transactions that can be conducted via IIAs. These include: Receiving interest and other legal income when conducting stock purchase transactions that do not require