Pursuant to Article 9.4 of the VTA's Rules, if the Respondent fails to submit the Statement of Defence, the arbitral proceedings shall still proceed.

By virtue of the independence and differences between the Statement of Defence and the Counterclaim, they cannot be merged. 

Pursuant to Article 10.1 of the VTA's Rules, the Respondent shall have the right to file a counterclaim against the Claimant. The counterclaim must be based on the arbitration agreement on which the Claimant has relied to make the Request for Arbitration against the Respondent. The Counterclaim shall be made in a separate document and submitted to the Centre at the same time as and with the submission of the Statement of Defence.

Pursuant to Article 10.3 of VTA's Rules, the Counterclaim and the relevant documents shall be submitted in a sufficient number of copies in accordance with paragraph 1 of Article 3 of the Rules.

Pursuant to Article 10.2 of VTA's Rules of Arbitration, the Counterclaim shall contain the following information:

a) Date, month, year on which the Counterclaim is made;

b) Names and addresses of the parties;

c) Summary of the content of the Counterclaim;

d) Grounds for the counterclaims;

đ) Monetary value of the Counterclaim and other claims of the Respondent;

e) Signature of the legal representative or the authorized representative where the Respondent is an organization; signature of the individual or the authorized representative where the Respondent is an individual.

According to Article 34 of VTA's Rules of Arbitration, costs of arbitration include:

1. The expenses for remuneration of Arbitrators;

2. The Centre’s administrative expenses;

3. The expenses for travelling, accommodation and other relevant expenses of the Arbitrators as stipulated in the written Guidelines of the Centre in force at the time of preparing the estimate for the expenses; and the expenses for other assistance at the request of the Arbitral Tribunal.

4. The expenses for inspection and valuation of assets, the expenses for seeking expert advice.

According to Article 35 of VTA's Rules of Arbitration, unless otherwise agreed by the parties, upon submission of the Request for Arbitration, the Claimant shall pay the expenses in full as provided in paragraphs 1 and 2 of Article 34 of these Rules pursuant to the Schedule of Costs of Arbitration of the Centre in force at the time of submission of the Request for Arbitration. Where the Claimant fails to pay such expenses in full within the period of time fixed by the Centre, the Claimant shall be deemed to have withdrawn the Request for Arbitration, but shall not be prevented from resubmitting the Request for Arbitration .

The expenses referred to in paragraphs 3 of Article 34 of these Rules shall be made in advance after the Arbitral Tribunal is constituted. The Centre shall consult with the Arbitral Tribunal to prepare the estimate of expenses and shall request a party or the parties to make in advance the expenses and notify the parties. Unless otherwise agreed by the parties, the requested party or parties shall make in advance the expenses in full within 15 days from the date of receipt of the notice from the Centre. If the expenses are not made in advanced in full, the Centre may request the Arbitral Tribunal to temporarily suspend the dispute resolution. In such a case, one party may make an advance on behalf of the other party at the request of the Centre so that the dispute resolution continues. If the expenses are not made in advanced in full, the Arbitral Tribunal may temporarily suspend the dispute resolution.

The expenses referred to in paragraph 4 of Article 34 of the Rules shall be paid in accordance with the regulation at paragraphs 3 and 4 of Article 19 of the Rules.

The Centre shall calculate the expenses as provided in paragraph 3 of Article 34 of these Rules and notify the parties and the Arbitral Tribunal before the Arbitral Tribunal makes the Arbitral Award. If the advanced amount exceeds the actual expenses, the Centre shall refund the excess amount. If the actual expenses exceed the advanced amount, the parties shall pay the Centre the additional amount. 

VTA does not have provisions of partial payment. According to Article 35 of VTA's Rules of Arbitration upon submission of the Request for Arbitration, the Claimant shall pay the expenses in full as provided. 

The costs of arbitration  should be transferred to the following account:

 Account No: 1339007 (VND)

 Name of bank: A Chau Commercial Joint Stock Bank

 The beneficiary: Vietnam Traders Arbitration Centre

According to Article 35.1 of VTA's Rules of Arbitration, where the Claimant fails to pay such expenses in full within the period of time fixed by the Centre, the Claimant shall be deemed to have withdrawn the Request for Arbitration, but shall not be prevented from resubmitting the Request for Arbitration

According to Article 35.2 of VTA's Rules of Arbitration, where the Respondent fails to pay such expenses in full within the period of time fixed by the Centre, the Respondent shall be deemed to have withdrawn the Counterclaim.