62/2009) would apply.
Under the basic provisions of his contract with PMG, Mr Panucci will spend more than 183 days in Vietnam during
the first 12-month consecutive period from his first arrival on 1 July 2012. However, it would be possible to be more
flexible with the number of days in Vietnam in the calendar year of 2012 (i.e. he can be present for less than 183
days in Vietnam during the period from 1 July to 31 December 2012). Accordingly, PMG thinks that it may be more
tax efficient for Mr Panucci in the period 2012–2013 if he were to spend less than 183 days in Vietnam in the year
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