II SÉRIE-A — NÚMERO 78 98_______________________________________________________________________________________________________________

AGREEMENT

BETWEEN

THE PORTUGUESE REPUBLIC

AND

THE SOCIALIST REPUBLIC OF VIET NAM

FOR

THE AVOIDANCE OF DOUBLE TAXATION

AND

THE PREVENTION OF FISCAL EVASION

WITH RESPECT TO TAXES

ON INCOME

The Portuguese Republic and the Socialist Republic of Viet Nam,

Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal

evasion with respect to taxes on income, in order to promote and strengthen the economic relations between

the two countries,

Have agreed as follows:

ARTICLE 1

Persons Covered

This Agreement shall apply to persons who are residents of one or both of the Contracting States.

ARTICLE 2

Taxes Covered

1. This Agreement shall apply to taxes on income imposed on behalf of a Contracting State or of its

political or administrative subdivisions or of its local authorities, irrespective of the manner in which they are

levied.

2. There shall be regarded as taxes on income 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

amounts 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 in particular:

(a) in Viet Nam:

(i) the personal income tax; and

(ii) the business income tax;

(hereinafter referred to as “Vietnamese tax”); and

(b) in Portugal:

(i) the personal income tax (Imposto sobre o Rendimento das Pessoas Singulares – IRS);

(ii) the corporate income tax (Imposto sobre o Rendimento das Pessoas Colectivas – IRC); and

(iii) the surtaxes on corporate income tax (Derramas);