(1) This Agreement shall apply to taxes on income imposed on behalf of each Contracting State, 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, as well as taxes on capital appreciation.

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

• (a) in the case of Canada:
  • (i) the income taxes imposed by the Government of Canada under the Income Tax Act;
• (hereinafter referred to as "Canadian tax");
• (b) in the case of Vietnam:
  • (i) the personal income tax;
  • (ii) the profit tax;
  • (iii) the profit remittance tax;
• (hereinafter referred to as "Vietnamese tax").

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