Personal scope of tax treaty: residents of one or both Contracting States qualify for bilateral double taxation relief.

An agreement between India and Vietnam creates a double taxation avoidance framework; the Central Government has directed that the Agreement's provisions be given effect in India by notification after both States completed required internal procedures. Article 1 defines the personal scope: the Treaty applies to persons who are residents of one or both Contracting States, thereby identifying the class of taxpayers eligible for treaty relief.

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