of May 27, 1993
About avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income
Government of the Russian Federation and Government of the Socialist Republic of Vietnam,
being guided by the aspiration to sign the Agreement on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income,
agreed as follows.
This agreement is applied to persons who are persons with the permanent residence in one or in both Contracting States.
1. This agreement is applied to the taxes on the income levied in Contracting States irrespective of method of their collection.
2. All taxes levied from the total amount of the income or from their separate elements including taxes on the income from alienation of personal or real estate, taxes on the total amount of the salary and the monetary rewards paid by the companies and also capital gain taxes are considered as taxes on the income.
3. The existing taxes to which this agreement extends, in particular, are:
a) in Russia - the taxes levied according to the following Laws of the Russian Federation:
(i) "About the income tax of the companies and organizations";
(ii) "About tax on the income of banks";
(iii) "About tax on the income from insurance activity" and
(iv) "About the income tax from physical persons"
(further the referred to as "Russian taxes");
b) in Vietnam:
(i) individual income tax;
(ii) income tax and
(iii) tax on the translated profit
(further the referred to as "Vietnamese taxes").
4. This agreement is applied also to any other, in essence to similar taxes which will be levied in amendment or instead of the taxes specified in Item 3. Competent authorities of Contracting States will notify each other on important changes in their relevant tax laws.
1. For the purposes of this agreement if other does not follow from context:
a) the term "Russia" means the Russian Federation and when using in geographical sense means its territory, including the territorial sea, and also economic zone and the continental shelf concerning which this State can perform the sovereign rights and jurisdiction according to its domestic legislation and international law;
b) the term "Vietnam" means the Socialist Republic of Vietnam and when using in geographical sense includes:
(i) any zone out of the territorial sea of Vietnam which according to the laws of Vietnam and international law is the territory where Vietnam performs the sovereign rights concerning natural resources on seabed and in its subsoil;
(ii) the sea and airspace over the territory mentioned in the subitem (i) concerning any activities performed in connection with investigation and operation of the natural resources mentioned here;
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