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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


Taxes Covered

(1) This Convention shall apply to taxes on income imposed on behalf of each Contracting State or local authorities, irrespective of the manner in which they are levied.

(2) They shall be regarded as taxes on income all taxes imposed on total income, or on elements of income.

(3) The existing taxes to which this Convention shall apply are:

  • (A) With regard to the Socialist People’s Libyan Arab Jamahiriya:
    • (i) Real Estate Revenue Tax;
    • (ii) Agricultural Revenue Tax;
    • (iii) Taxes on Commercial, Industrial and Professional profits, which comprise:
      • (a) taxes on profits realized from commercial, industrial and professional activities;
      • (b) Taxes on Companies;
    • (iv) Taxes on profits realized by practising Fee Professions;
    • (v) Taxes on wages, salaries and the like;
    • (vi) Taxes on Income realized abroad;
    • (vii) General Tax on Income;
    • (viii) Al-Jihad Tax (Defence Tax);
    • (ix) Income arising from depositing money in banks and savings accounts.
  • (B) With regard to the Republic of India:
    • (i) The Income-tax including any surcharge thereon imposed under the Income-tax Act, 1961 (43 of 1961);
    • (ii) The surtax imposed under the Companies (Profits) Surtax Act, 1964 (7 of 1964).

(4) The Convention shall also apply to any identical or substantially similar taxes which are subsequently imposed in addition to, or in place of, the existing taxes. At the end of each year, the competent authorities of the Contracting States shall notify to each other any changes which have been made in their respective taxation laws.