4. Where, in an agreement for the avoidance of double taxation with another State, Vietnam provides for a rate of less than 10% of the gross interest rate as regards the taxation of interest referred to in Article 11(2), the lowest rate shall apply for the purposes of Article 11(2). In this way, the same income is taxed twice. The DBA facilitates this double taxation by allowing the Singaporean company to claim a deduction of foreign tax from its Singapore tax, which must be paid on the same income. As a preliminary matter, it should be noted that the objective of the Vietnam-Singapore Double Taxation Convention is to eliminate double taxation without creating opportunities for non-taxation or tax reduction through tax evasion or avoidance (including contractual purchase agreements).