S.L. 123.172 ст. 2Arrangements to have effect. THE The Republic of Desiring to prevention of Have agreed This Contracting 1. This Contracting 2. There income, or on movable or paid by 3. The (a) in (b) 4. The taxes that are in place of, the shall notify taxation laws. 1. For the Nam; when internal maritime areas over

It is hereby declared:

(a) that the arrangements specified in the Agreement set out in the Schedule to this Order (hereinafter referred to as "the Agreement") have been made with the Government of the Socialist Republic of Viet Nam with a view to affording relief from double taxation in relation to the following taxes imposed by the laws of the Socialist Republic of Viet Nam:

(i) the personal income tax; and

(ii) the business income tax;

(b) that it is expedient that those arrangements should have effect following the entry into force of the Agreement and in accordance with the relevant provisions of the Agreement;

(c) that the Agreement has entered into force on 25th November, 2016. SCHEDULE

Article 2 AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF MALTA AND GOVERNMENT OF THE SOCIALIST REPUBLIC OF VIET NAM FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME Government of the Republic of Malta and the Government of the Socialist Viet Nam, conclude an Agreement for the avoidance of double taxation and the fiscal evasion with respect to taxes on income, as follows: Article 1

PERSONS COVERED Agreement shall apply to persons who are residents of one or both of the States. Article 2 TAXES COVERED

Agreement shall apply to taxes on income imposed on behalf of a State, irrespective of the manner in which they are levied.

shall be regarded as taxes on income all taxes imposed on total elements of income, including taxes on gains from the alienation of immovable property and taxes on the total amounts of wages or salaries enterprises. existing taxes to which the Agreement shall apply are in particular: Viet Nam:

(i) the personal income tax; and

(ii) the business income tax; (hereinafter referred to as "Vietnamese tax"); and in Malta: the income tax; (hereinafter referred to as "Malta tax"). Agreement shall apply also to any identical or substantially similar imposed after the date of signature of the Agreement in addition to, or existing taxes. The competent authorities of the Contracting States each other of any significant changes that have been made in their

Article 3 GENERAL DEFINITIONS

purposes of this Agreement, unless the context otherwise requires:

(a) the term "Viet Nam" means the Socialist Republic of Viet used in a geographical sense, it means its land territory, islands, waters, territorial sea and airspace above them, the beyond territorial sea including seabed and subsoil thereof the Socialist Republic of Viet Nam exercises sovereignty, rights and jurisdiction in accordance with national legislation international law;

(b) the term "Malta" means the Republic of Malta and, when geographical sense, means the Island of Malta, the Island the other islands of the Maltese archipelago including waters thereof, as well as any area of the sea-bed, its sub-soil superjacent water column adjacent to the territorial waters, Malta exercises sovereign rights, jurisdiction, or control with international law and its national law, including relating to the exploration of the continental shelf and exploitation natural resources;

(c) the terms "a Contracting State" and "the other Contracting Viet Nam or Malta as the context requires;

(d) the term "person" includes an individual, a company and of persons;

(e) the term "company" means any body corporate or any treated as a body corporate for tax purposes;

(f) the terms "enterprise of a Contracting State" and "enterprise Contracting State" mean respectively an enterprise carried resident of a Contracting State and an enterprise carried on of the other Contracting State;

(g) the term "national", in relation to a Contracting State, means:

(i) any individual possessing the nationality of that State; and

(ii) any legal person, partnership or association deriving such from the laws in force in that Contracting State;

(h) the term "international traffic" means any transport by a operated by an enterprise of a Contracting State, except or aircraft is operated solely between places in the other State; and

(i) the term "competent authority" means:

(i) in the case of Viet Nam, the Minister of Finance or representative;

(ii) in the case of Malta, the Minister responsible for authorised representative.