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Pakistan - Vietnam Tax Treaty (2004) — Orbitax Tax Hub
Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


General Definitions

(1) For the purposes of this Agreement, unless the context otherwise requires:

  • (a) The term "Pakistan" when used in a geographical sense means Pakistan as defined in the constitution of the Islamic Republic of Pakistan and includes any area outside the territorial waters of Pakistan which under the laws of Pakistan and international law is an area within which Pakistan exercises sovereign rights and exclusive jurisdiction with respect to the natural resources of the seabed and subsoil and superjacent waters;
  • (b) The term "Vietnam" means the Socialist Republic of Vietnam; when used in geographical sense, it means all its national territory, including its territorial sea and any area beyond and adjacent to its territorial sea, within which Vietnam by Vietnamese legislation and in accordance with international law, has sovereign rights of exploration for and exploitation of natural resources of the seabed and its subsoil and superjacent watermass;
  • (c) The terms "Contracting State" and the "other Contracting State" mean Pakistan or Vietnam as the context requires;
  • (d) The term "person" includes an individual, a company and any other body of persons;
  • (e) The term "company" means any-body corporate or any entity that is treated as a body corporate for tax purposes;
  • (f) The terms "enterprise of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State;
  • (g) The term "national" means:
    • (i) any individual possessing the nationality of a Contracting State;
    • (ii) any legal person, partnership or association deriving its status as such from the laws in force in a Contracting State.
  • (h) The term "international traffic" means any transport by a ship or aircraft operated by an enterprise in a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State; and
  • (i) The term "competent authority" means:
    • (i) in case of Pakistan, the Central Board of Revenue or its authorized representative; and
    • (ii) in the case of Vietnam, the Minister of Finance or his authorized representative;
  • (j) The term "tax" means Pakistan tax or Vietnamese tax, as the context requires.

(2) As regards the application of the Agreement at any time by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that State concerning the taxes to which the Agreement applies, any meaning under the applicable tax laws of that State prevailing over a meaning given to the term under other laws of that State.