Non-discrimination in taxation ensures equal treatment of foreign nationals and enterprises with a capped profit remittance tax exception.

Non-discrimination mandates equal taxation and connected requirements for nationals and comparable enterprises of a Contracting State when in the other State; permanent establishments must be taxed no less favourably than domestic enterprises carrying on the same activities, subject to the Agreement's provisions. Non-residents need not be granted resident-only personal allowances. Enterprises owned or controlled by residents of the other State are protected against more burdensome taxation, except that the rules on permanent establishments and controlled-capital enterprises do not apply to the Vietnamese profit remittance tax (which is capped) or to taxation of agricultural production. "Taxation" means the taxes covered by the Agreement.

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