(1) This Agreement shall apply to taxes on income imposed on behalf of a Contracting State or of its political subdivisions or local authorities, irrespective of the manner in which they are levied.
(2) There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property and taxes on the total amounts of wages or salaries paid by enterprises.
(3) The existing taxes to which the Agreement shall apply are in particular:
- (a) in the case of the Republic of Indonesia:
- (i) the income tax
- (hereinafter referred to as "Indonesian tax");
- (b) in the case of the Republic of India:
- (i) the income tax, including any surcharge thereon
- (hereinafter referred to as "Indian tax").
(4) The Agreement shall also apply to any identical or substantially similar taxes that are imposed after the date of signature of the Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes that have been made in their respective taxation laws.