Covid-19 and Legal Perspective on Force Majeure

Covid 19 and Force Majeure

On 1st Feb 2020 in Vietnam, the Prime Minister issued Decision No. 173/QD-TTg about the Declaration of Covid-19 epidemic – novel coronavirus acute respiratory disease[1] (“Covid-19”). On that basis, recently the State authorities have issued a number of documents to prevent and control this Covid-19, which may have affected company’s production, business and human resources activities, as well as the ability to perform contractual obligations previously concluded.

Therefore, QNT Law Firm would like to send this Legal Update to you in order to help you get a basic view on some of legal issues related to Covid-19, namely: Force Majeure and Basic Change of Circumstances under laws of Vietnam. Hopefully this document will be useful to you in the meantime.

1.       Force Majeure

Under the provisions of laws of Vietnam, where an obligor is not able to perform a civil obligation due to an event of force majeure, it shall not have civil liability[2], commercial liability[3] unless otherwise agreed or otherwise provided by law.

In particular, a force majeure event (“Force Majeure”) is understood to be an event which occurs in an objective manner which is not able to be foreseen and which is not able to be remedied by all possible necessary and admissible measures being taken[4]. Accordingly, to an event is called Force Majeure when:

  • An event occurs in an objective manner which is not able to be foreseen; and
  • (Consequences of the event/Liability) which is not able to be remedied (by the exempt Party) by all possible necessary and admissible measures being taken.

In connection with the Covid-19, we understand that:

  • Firstly, emphasize that, the Prime Minister’s Decision on the declaration of Covid-19 above is not a sufficient legal basis so that you do not have to bear civil and commercial liability due to the Force Majeure.
  • Secondly, the Prime Minister’s Decision on the declaration of Covid-19 above is the legal basis for determining that the Covid-19 is an objective manner occurrence[5] – only one of the conditions for obtaining the Covid-19 could be considered a Force Majeure to waive liability for the exempt Party.
  • Thirdly, when the Covid-19 may referred to as an force majeure event to waive liability for its failed obligations, the obligor must prove[6] that it failed to remedy the consequences of the event (cause of failure to comply with the obligations), although he/his has taken all necessary measures in its permissible capacity to remedy them.

In addition, from 18 December 2015, Vietnam officially ratified the accession to the Vienna Convention on the Contract of International Sales of Goods of the United Nations (CISG). In particular, Clause 1, Article 79 of the CISG also provides for exemption of liability, specifically: “A party is not liable for a failure to perform any of his obligations if he proves that the failure was due to an impediment beyond his control and that he could not reasonably be expected to have taken the impediment into account at the time of the conclusion of the contract or to have avoided or overcome it or its consequences.”.

The exemption of liability due to a Force Majeure shall be determined on a case-by-case basis, on the basis of consideration of the Parties’ lawful terms of agreement on definitions, conditions of application and legal consequences, etc. of the Force Majeure stipulated in the signed Contract.

2.       Basic Change of Circumstances

Under the provisions of laws of Vietnam, in the case of basic circumstances change, the affected party may request the other party to the re-negotiate the contract in a reasonable period of time[7].

In particular, the basic change of circumstances (“BCC”) is construed as having fully met the following conditions:

  • The circumstances change due to objective reasons occurred after the conclusion of the contract;
  • At the time of concluding the contract, the parties could not foresee a change in circumstances;
  • The circumstances change such greatly that if the parties know in advance, the contract has not been concluded or are concluded, but with completely different content;
  • The continuation of the contract without the change in the contract would cause serious damage to one party;
  • The party having interests adversely affected has adopted all the necessary measures in its ability, in accordance with the nature of the contract, cannot prevent or minimize the extent of effect. [8]

The BBC and Force Majeure are mainly different in the following:

CriteriaForce MajeureBasic Change of Circumstances
DesireThe obligor wishes to be exempt from liability.The affected party wishes to renegotiate the Contract.
ConditionsRequests cannot overcome the consequences of an event even though all necessary measures have been taken in its ability (they cannot fulfill their obligations).Requests has taken all necessary measures in its ability, in accordance with the nature of the contract, cannot prevent or minimize the extent of effect (they cannot prevent, minimize damage).

In connection with the Covid-19, we understand that:

  • Firstly, the Prime Minister’s Decision on the declaration of Covid-19 above is the legal basis for determining the condition of “objective reasons occurred”.
  • Secondly, the affected Party must basically demonstrate the following issues:
  • There is a great change in the circumstances of Contract performance compared to the signed time.
  • Serious damage to them if the content of the Contract is not changed.
  • It has taken all necessary measures in its ability, consistent with the nature of the Contract but could not prevent, minimize the extent of effect.

Therefore, if the consequences of the Covid-19 cause serious damage when performing the Contract, you can consider applying this BCC provision. If the Parties cannot reach an agreement on amending the Contract within a reasonable period of time, any of the Parties may request a Court to handle. Note that, in the process of negotiating amendments and termination of the Contract and the Court handling the case, the Parties must continue to perform its obligations under the Contract, unless otherwise agreed.


[1] Replaced by the Prime Minister’s Decision No. 447/QD-TTg dated April 1, 2020

[2] Clause 2 Article 351 Civil Code No. 91/2015/QH13

[3] Point (b) Clause 1 Article 294 Law on Commercial No. 36/2005/QH11

[4] Clause 1 Article 156 Civil Code No. 91/2015/QH13

[5] This issue is based on information officially published in Vietnam.

[6] Clause 2 Article 294 of Law on Commercial stipulates: “The contract-breaching party shall bear the burden of proof of cases of liability exemption

[7] Clause 2 Article 420 Civil Code No. 91/2015/QH13

[8] Clause 1 Article 420 Civil Code No. 91/2015/QH13

New substances of Circular No.39/2016/TT-NHNN

NEW SUBSTANCES OF CIRCULAR NO.39/2016/TT-NHNN

    On 30 December 2016, the Circular No. 39/2016/TT-NHNN (“Circular 39”) was promulgated by the State Bank of Vietnam and replaced Decision No. 1627/2001/QD-NHNN (hereinafter referred to as “Replaced Documents”) is effective from 15 March 2017 on the Regulation on lending activities of credit institutions and foreign bank branches to customers.

    According to our understanding, the Circular 39 has some new important points about the legal status of borrowers, purposes of borrowing, loan interest rate, loan term, sample credit contract, publication of conditions, overdue debt transfer and debt collection order.

    Specifically, the Circular 39 has some important changes to be considered as follows:

    1. Legal status of Borrowers

    The Circular 39 stipulated that “Customer performing a borrowing transaction with a credit institution (hereinafter referred to as borrowing customer) refers to any legal entity or individual, including: a) Legal entities established and operated within the territory of Vietnam and/or those established abroad and legally operated within the territory of Vietnam; b) Vietnamese and/or foreign nationals.”[1]

    We realize that the difference in this new substance is the customer performing a borrowing transaction with a credit institution only includes legal entities and individuals. It means that organizations being non-legal entity (e.g. households, cooperative groups, private enterprises, other non-legal entities) are not entitled to borrow capital from credit institutions. This is also consistent with the provisions in the Civil Code 2015[2].

    Previously, the Replaced Documents stipulated that customers borrowing from credit institutions shall be Vietnamese and foreign organizations, individuals that are capable of repayment and have demand for funds borrowing…, means that the replaced law allows the borrowers to include households, cooperative groups, private businesses or partnerships company.

    2. Purposes of Borrowing

    In Circular 39, there are two (2) groups of loan purposes, including: Consumer loan and Business loan, namely:

    • Consumer loan means “a credit institution’s granting a loan to an individual customer’s demands for borrowed funds to pay consumption or living expenses for his/her personal or family purposes[3]; and

    • Business loan means “a credit institution’s granting a loan to a legal entity or individual to meet the demands for borrowed funds other than those referred to in Clause 4 of this Article (Consumer loan), including the demands for borrowed funds by that legal entity or individual, and the demands for borrowed funds by a business household or private company of which that individual is the legal owner[4].

    We realize that the difference in this new substance is the fact that the Circular 39 does not limit the purposes of borrowing as the Substitute Documents, which divides the demand for loans into the two groups mentioned above. Previously, the Replaced Documents have limited the loan purposes of customers in the implementation of investment projects, plan of production, business and service activity or investment projects, plan of domestic and overseas living standard improvement.

    It should be noted that, according to the Circular 39, although the organizations being non-legal entity will be not entitled to borrow capital from credit institutions, but the Circular 39 allows the credit institutions grant a loan to individual customer who is the head of household business or owner of private enterprise to meet the capital needs of business households and private enterprises.

    3. Loan Re-Structuring

    For the loan re-structuring, the Circular 39 stipulated that Credit institutions shall not be allowed to approve the following loan demands:

    • Loans used for repaying loan debts owed to lending credit institutions, except for those used for paying loan interest arising during the construction process of which cost is accounted for in the construction cost estimate approved by a regulatory authority in accordance with laws.

    • Loans used for repaying loan debts owed to other credit institutions and foreign loan debts, except for loans used for repaying debts prior to the payment due date that fully meet the following requirements:

    a) Be a loan used for business activities;

    b) Have the loan term that does not exceed the residual loan term of an older loan;

    c) Be a loan under which the debt rescheduling has not been carried out[5].

     We realize that Circular 39 has a change in the loan re-structuring regulations compared with the Replaced Documents with a view to tighten controlling over lending to repayment.

    4. Loan interest rate

    The Circular 39 stipulated that,

    • Maximum interest rate: “A credit institution and its customer shall agree on the interest rate depending on capital demands and supplies on the market, loan demands and creditworthiness of customers[6], unless otherwise the interest rate on short-term loan denominated in Vietnamese dong “shall not allow it to exceed the maximum interest rate decided by the State Bank’s Governor over periods of time in order to meet certain demands for borrowed fund[7];

    • Late payment interest: If a customer fails to make due payment of interest, “the customer must pay late payment interest charged at the interest rate agreed upon between the credit institution and customer which is not allowed to exceed 10%/year interest rate on the outstanding balance of late payment interest in proportion to the period of late payment[8];

    • Interest on the overdue principal: Where a debt has become delinquent, “the customer owing a delinquent debt must pay interest on the outstanding amount of principal which is overdue in proportion to the period of late payment for which the interest rate charged is not allowed to exceed 150% of the interest rate charged on due repayment that is determined upon the date of such debt becoming delinquent[9]

    • Variable interest rate: Where the variable interest rate is applied, “a credit institution and customer must enter into an agreement on principles and factors for determination of the variable interest rate, and on the date of adjustment to the loan interest rate. In cases where referring to factors for determination of the variable interest rate results in different loan interest rates, the credit institution shall apply the lowest loan interest rate[10].

    We realize that the importance in this new substance is the fact that the regulation of maximum interest rate applies only to case of the short-term loan denominated in Vietnamese dong in the priority areas stipulated in Circular 39. Furthermore, in addition to the interest on the principal, there was a clear regulation of the maximum and the calculation of the late payment interest, the interest on the overdue principal and the variable interest rate in order to avoid conflict in the understanding of the parties.

    5. Loan term

    The Circular 39 stipulated that,

    • Loan term refers to “a period of time starting on the day following the day when a credit institution begins to disburse the borrowed fund to a customer and ending on the day when that customer has to repay principal and interest amounts in full as agreed upon between the credit institution and customer[11];

    • Credit institutions will grant a decision into the following categories:

    • Short-term loan, defined as loans having the maximum loan term of 01 (one) year.

    • Medium-term loan, defined as loans having the loan term between above 01 (one) year and 05 (five) years at the maximum.

    • Long-term loan, defined as loans having the loan term of more than 05 (five) years[12].

    We realize that the difference in this new substance is (i) the loan term is not calculated from the received time of the loan by clients; and (ii) the loan term is determined by year rather than month.

    6. Some other substances

    • Currency of repaying debts: Besides the regulations on currency of lending in the same previously, the Circular 39 has a substance specifically on currency of repaying debts – “Currency unit used for debt repayment is the one used in a loan[13].

    • Fee paid for a commitment to borrowed fund: The Circular 39 has a substance on Fee paid for a commitment to borrowed fund, specifically the credit institution and customers can agree on the payment of “Fee paid for a commitment to borrowed fund withdrawal during the period from the date of entry into force of the loan agreement to the date of initial disbursement of borrowed fund[14].

    • Penalty and compensation: Circular 39 stipulated that credit institutions and customers have the right to agree on penalties and compensation in case of defaulting on a loan, unless otherwise the loan principal and/or interest. Also, we note that, if there is not an agreement on both of penalty and compensation, the defaulting party shall only be subject to the penalty for violation (without compensation)[15].

    • Delinquent debt: The Circular 39 stipulated that “The credit institution shall perform delinquency procedures for the principal amount of which repayment is not made by the agreed due date and rescheduling is not accepted by the credit institution”[16]. The difference in this new substance is a replacement of “the whole outstanding amount of debt” with “the outstanding amount of principal of customers cannot repay on time” – This is a rule to avoid conflict in the understanding of the parties in past.

    • Post the contract templates, general conditions of lending: The Circular 39 stipulated that the credit institution shall be obliged to

    • Make a public notice of such contract templates and general contractual terms and conditions regarding lending activities at its office, and make posts on its website;

    • Provide a full amount of information about these contract templates and general terms and conditions of which a customer should be informed prior to conclusion of a loan agreement, and obtain customer’s confirmation that the credit institution has already provided all necessary information[17].

    • Notify early debt recovery: Upon delinquency, debt termination and debt recovery prior to the agreed due date, the credit institution shall notify the customer of such delinquency, loan termination and early debt recovery[18].

    ________________________________________________

    [1] Clause 3 Article 2 of Circular No. 39/2016/TT-NHNN

    [2] Civil Code No. 91/2015/QH13 dated 24 month 11 year 2015 by the National Assembly XIII of Viet Nam

    [3] Clause 4 Article 2 of Circular No. 39/2016/TT-NHNN

    [4] Clause 5 Article 2 of Circular No. 39/2016/TT-NHNN

    [5] Clause 5 and 6 Article 8 of Circular No. 39/2016/TT-NHNN

    [6] Clause 1 Article 13 of Circular No. 39/2016/TT-NHNN

    [7] Clause 2 Article 13 of Circular No. 39/2016/TT-NHNN

    [8] Clause 4(b) Article 13 of Circular No. 39/2016/TT-NHNN

    [9] Clause 4(b) Article 13 of Circular No. 39/2016/TT-NHNN

    [10] Clause 5 Article 13 of Circular No. 39/2016/TT-NHNN

    [11] Clause 8 Article 2 of Circular No. 39/2016/TT-NHNN

    [12] Article 10 of Circular No. 39/2016/TT-NHNN

    [13] Clause 2 Article 11 of Circular No. 39/2016/TT-NHNN

    [14] Clause 4 Article 14 of Circular No. 39/2016/TT-NHNN

    [15] Article 25 of Circular No. 39/2016/TT-NHNN

    [16] Article 20 of Circular No. 39/2016/TT-NHNN

    [17] Clause 4 Article 23 of Circular No. 39/2016/TT-NHNN

    [18] Article 20 and Clause 1 Article 21 of Circular No. 39/2016/TT-NHNN

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    @ Copyright 2017 – QNT Law Firm – The article was written within and complies with the relevant legislation at the published time

     

     

    Legal information about Investment in Vietnam

    LEGAL INFORMATION ABOUT INVESTMENT IN VIETNAM

      1.      Policies and Guarantees on Investment

      1.1. Guarantee of asset ownership

      Under the Law on Investment, the Vietnamese State shall recognize and protect the ownership of assets, capital, income, other lawful rights and interests of investors. Lawful assets of investors shall not be nationalized or confiscated by administrative measures.

      Moreover, the remittance of assets of foreign investors overseas is guaranteed. After all financial obligations to Vietnamese Government are fulfilled, foreign investors are permitted to transfer the following assets to abroad: (i) capital and liquidations; (ii) income from business investment; and (iii) money and other assets under the lawful ownership of the investors.

      1.2. Guarantee of Business Investments 

      Under the Law on Investment, investors are permitted to make at their discretion decisions on business investment activities in accordance with the Law on Investment and relevant laws; to have access to and use credit funds and support funds and use land and other resources in accordance with law.

      Moreover, where a new legal instrument which is promulgated provides greater investment incentives than those which the investor currently is enjoying, the investor is entitled to enjoy the investment incentives in accordance with the new legal instrument for the remaining duration in which the project is entitled to incentives.

      Where a new legal instrument which is promulgated provides lower investment incentives than those which the investor has previously enjoyed, the investor shall continue to be entitled to the investment incentives in accordance with the previous regulations for the remaining duration in which the project is entitled to incentives (except changed for reason of national defense and security, social order and safety, social morals, the health of the community or environmental protection).

      2. Line of Business 

      Prohibited business: In Vietnam, investors are entitled to conduct business investment activities in industries and trades which are not prohibited by the Law on Investment. There are some business activities in which investment is prohibited for both foreign and domestic investors, such as: business in narcotic substances, prostitution, humans or parts of human body, and some specific others.

      Conditional business: In addition, there are a number of business activities in which the investment must satisfy certain conditions stipulated by the Government, such as: securities trading, insurance, casino business, logistics services, mineral trading, employment agency services, real estate trading, telecommunications services, and some specific others.

      Incentives business: Conversely, the Vietnamese State shall encourage and have a policy of incentives applicable to investment in preferential investment sectors and geographical areas, such as:

      • For preferential investment sectors: high-tech activities; production of new materials, new energy, clean energy, electronics, specific agricultural machinery, automobiles, information technology, software, and some others.

      • For preferential investment geographical areas and stature: scale of capital being VND 6,000 billion; investment projects located in rural areas and employing 500 employees or more; areas with difficult socio-economic conditions; industrial zones, export processing zones, high-tech zones and economic zones, and some others.

      3. Forms of Investment 

      The Law on Investment stipulates some forms of investment in Vietnam, namely:

      • Investment for establishment of economic organization;

      • Investment in the form of capital contribution or purchase of shares or portion of capital contribution to economic organizations;

      • Investment in the form of public private partnership contract (PPP Contract); and

      • Investment in the form of business co-operation contract (BCC Contract).

      We note that, for the investment in establishment of a business organization (enterprise), the foreign investor must have an investment project and apply for a Certificate of Investment Registration under Law on Investment.

      In addition, when a foreign entity does not want to invest in Vietnam, but it desires to have a business presence in Vietnam, it can set up a branch or a representative office in Vietnam.

      4. Types of Enterprises

      Investors may establish an economic organization (enterprise) in accordance with Law on Enterprises, including the following basic types of enterprise:

      • SOLE PROPRIETORSHIP is an enterprise owned by an individual who is responsible for its operation with all of his/her property.

      • ONE MEMBER LIMITED LIABILITY COMPANY is an enterprise under the ownership of an organization or individual (the company’s owner) who is liable for the company’s debts and other liabilities up to the company’s charter capital.

      • TWO AND MORE MEMBER LIMITED LIABILITY COMPANY is an enterprise under the ownership of organizations and/or individuals (the company’s members in the number of members does not exceed 50). The members are liable for debts and other liabilities of the enterprise up to the value of “contributed capital”. Stakes of members shall be transferred in accordance with the Law on Enterprises.

      • JOINT-STOCK COMPANY is a enterprise under the ownership of organizations and/or individuals (the company’s shareholders in the minimum quantity of shareholders is 03). The shareholders are only liable for the enterprise’s debts and other liabilities up to the value of “contributed capital”. Shareholders are entitled to transfer their shares to other persons in accordance with the Law on Enterprises. Joint-stock companies are entitled to issue various types of shares to raise capital.

      The enterprise shall be granted the Certificate of Business registration when The application for business registration is satisfactory under Law on Enterprises. In order to operate in the conditional business, the enterprise should satisfy the legal conditions and obtain the corresponding sub-license in accordance with the law of Vietnam.

        ________________________________________________

        @ Copyright 2015 – Công ty Luật QNT – The article is written within and under the Law on Investment No. 67/2014/QH13 dated on 26 Nov 2014 and the Law on Enterprises No 68/2014/QH13 dated on 26 Nov 2014.

        Some things to know about management of One-member LLC

        SOME THINGS TO KNOW ABOUT MANAGEMENT OF

        ONE MEMBER LIMITED LIABILITY COMPANY

          Law on Enterprises 2014 was passed by the National Assembly on 26 November 2014 and will officially take full effect as from 01 July 2015 (“LOE 2014”). This LOE 2014 has created significant changes on regulations and had continuously a vital role of forming favorable business environment for enterprises in Viet Nam.

          In this connection, there are some important changes of LOE 2014, such as: simplification of license requirements; more than one legal representative permitted; lower quorum and voting thresholds in LLC and JSC; new reporting duties regarding change of managers; fewer restrictions on founding shareholders in JSC; etc.

          Hence, QNT Law Firm would like to issue this Legal Update in order to assist the clients in catching some legislative changes under LOE 2014 relating to management of one member limited liability company (“One Member LLC”).

          1. Rights and obligations of the Company Owner

          Firstly, the definition of One Member LLC under LOE 2014 compared to LOE 2005 is a similar. One Member LLC is an enterprise owned by one organization or individual (“Company Owner”), the Company Owner is liable for all debts and other property obligations of the company to the extent of the amount of the charter capital of the company.

          1.1. Rights of the Company Owner

          Under LOE 2014, the Company Owner has the following typical rights[1]:

          • To make decisions on the company’s charter, on developmental strategies and annual business plans, on projects for investment and development;

          • To make decisions on the organizational and managerial structure of the company, and to appoint the company’s managers;

          • To make decisions on increase in charter capital; on assignment of all or part of the charter capital;

          • To make decisions on use of profit after fulfilment of tax obligations and other financial obligations of the company; on re-organization or dissolution and petition for bankruptcy of the company.

          In addition, the Company Owner being an organization has other rights as follows:

          • To approve loan agreements and other contracts as stipulated in the company’s charter valued at fifty (50) or more per cent of the total value of the company’s assets[2];

          • To make decisions on sale of assets valued at fifty (50) or more per cent of the total value of the company’s assets[3].

          We are especially noted that if the Clients do not want to perform directly the rights mentioned above, the Clients must authorize the chairman implement them via a Power of Attorney.

          1.2. Obligations of the Company Owner

          Under LOE 2014[4], Besides the basic obligation of the Company Owner such as: to contribute the charter capital; to comply with the charter and laws; to identify and separate assets of the Company Owner from assets of the company. We are especially noted that Company Owner may withdraw capital only by way of assignment of a part or all of the charter capital to other organizations and individuals; in the case of withdrawal of all or part of its contributed charter capital from the company in another form, the Company Owner and the organization or individual concerned must be jointly liable for debts and other property obligations of the company.

          Furthermore, the Company Owner may not withdraw profit in cases where the company has not paid in full all debts and other property obligations which are due.

          1. Organizational and managerial structure of One Member LLC

          1.1. Managerial structure of One Member LLC owned by an organization

          Under LOE 2014[5], One Member LLC owned by an organization shall be organized, managed and operate in either of the following models:

          a. Chairman, General Director and Inspector(s)

          QNT LG One Member LLC

          b. Members’ Council, General Director and Inspector(s)

          QNT LG OM LLC

          2.2. Management structure of One Member LLC owned by an individual

          Under Law on Enterprise 2014[6], One Member LLC owned by an individual shall have a Chairman and a General Director. The Chairman may act concurrently or employ another person as the General Director.

          3. Contracts and transactions of One Member LLC with the related persons

          Under LOE 2014[7], any contract or transaction between One Member LLC owned by an organization and the following persons must be considered and decided by the Members’ Council or Chairman, Director/General Director and Inspector(s):

          1. Company Owner and Related Person[8] of Company Owner;
          2. A member of Members’ Council, Director/General Director and Inspectors;
          3. Related Person of the persons stipulated in point (ii) mentioned above;
          4. A manager of Company Owner, the person authorized to appoint such managers;
          5. A related person of the persons stipulated in sub-clause (d) of this clause.

          We are especially noted that:

          • The signatory of the contract must notify Members’ Council or Chairman, Director/General Director and Inspectors of entities involved in such contract or transaction; and concurrently enclose the draft of such contract or main contents of such transaction.
          • A contract or transaction shall be void and dealt with in accordance with law where it is not entered into in accordance with the relevant provisions, causing loss and damage to the company. The signatories to the contract and related persons being the parties to the contract must be jointly responsible for any loss arising and for returning to the company any benefit gained from the performance of such contract or transaction.
          • A contract or transaction between One Member LLC owned by an individual and Company Owner or Related Person of Company Owner must be recorded and retained as a separate file of the company.

          ________________________________________________

          [1] Article 75 of LOE 2014

          [2] Or a smaller percentage or value as stipulated in the company’s charter

          [3] Or a smaller percentage or value as stipulated in the company’s charter

          [4] Article 76 of LOE 2014

          [5] Article 78, 79, 80, 81 and 82 of LOE 2014

          [6] Article 85 of LOE 2014

          [7] Article 86 of LOE 2014

          [8] Related Person is defined in Clause 18 Article 4 of LOE 2014

          ________________________________________________

          @ Copyright 2015 – Công ty Luật QNT 

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