AGREEMENTS BETWEEN THE GOVERNMENT OF THE REPUBLIC OF KAZAKHSTAN AND GOVERNMENT OF THE SOCIALIST REPUBLIC OF VIETNAM

of October 31, 2011

About avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income

The government of the Republic of Kazakhstan and the Government of the Socialist Republic of Vietnam, being guided by the aspiration to strengthen and develop commercial, scientific, technical and cultural ties between both Contracting States and wishing to sign the Agreement on avoidance of the double taxation and prevention of evasion from the taxation concerning taxes on the income,

agreed as follows:

Article 1. Persons to whom the agreement is applied

This agreement is applied to persons who are residents of one or both Contracting States.

Article 2. Taxes to which the agreement extends

1. This agreement is applied to the taxes on the income levied on behalf of the Contracting State or its regional authorities irrespective of method of their collection.

2. All types of tax levied from total of income or from separate elements of the income including taxes on the income from alienation of personal or real estate, taxes levied from the total amount of salary or the salary 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 are in particular:

a) in Kazakhstan:

(i) corporate income tax;

(ii) individual income tax;

(further referred to as as "The Kazakhstan taxes");

b) in Vietnam:

(i) the income tax from physical persons;

(ii) tax on entrepreneurial incomes;

(further referred to as as "The Vietnamese taxes").

4. This agreement is also applied to any identical or in essence to similar taxes which will be levied after signature date of this agreement in amendment or instead of the existing taxes. Competent authorities of Contracting States will notify each other on any essential changes which will happen in the corresponding tax national legal systems their Agreeing the States.

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