(1) This Agreement shall apply to taxes on income 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 all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property, and taxes on the total amounts of wages or salaries paid by enterprises.

(3) The existing taxes towhich the Agreement shall apply are in particular:

• (a) in New Zealand:
  • (i) the income tax;
• (hereinafter referred to as "New Zealand tax");
• (b) in Vietnam:
  • (i) the personal income tax; and
  • (ii) the business income tax;
• (hereinafter referred to as "Vietnamese tax").

(4) The Agreement shall apply also to any identical or substantially similar taxes that 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 any significant changes which have been made in their respective taxation laws.