The Double Taxation Relief (Taxes on Income) (Vietnam) Order 1994

Article 2 Taxes covered

(1) This Agreement shall apply to taxes on income and on capital gains imposed on behalf of a Contracting State irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income and on capital gains all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property, taxes on the total amount of wages or salaries paid by enterprises as well as taxes on capital appreciation.

(3) The existing taxes to which the Agreement shall apply are:

(a) in the United Kingdom:

(i) the income tax;

(ii) the corporation tax; and

(iii) the capital gains tax;

(hereinafter referred to as “United Kingdom tax”);

(b) in Vietnam;

(i) the income tax;

(ii) the profits tax;

(iii) the profit remittance tax;

(iv) the foreign petroleum sub contractor tax;

(v) the foreign contractor tax;

(hereinafter referred to as “Vietnamese tax”).

(4) The Agreement shall also apply to any identical or substantially similar taxes which are imposed by either Contracting State after the date of signature of this Agreement in addition to, or in place of, the existing taxes.The competent authorities of the Contracting States shall notify each other of any substantial changes which have been made in their respective taxation laws.