background image
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.

ARTICLE 2

Taxes Covered

(1) The taxes to which this Agreement shall apply are:

  • (a) in the Republic of India:
    • (i) the income tax; including any surcharge thereon
  • (hereinafter referred to as "Indian tax");
  • (b) in the Union of Soviet Socialist Republics:
    • (i) income tax on foreign legal persons;
    • (ii) income tax on population; and
    • (iii) tax on part of profits of a foreign participant of a joint venture imposed when it is transferred abroad;
  • (hereinafter referred to as "the U.S.S.R. tax").

(2) The Agreement shall also apply to any identical or substantially similar taxes which are imposed by either Contracting State after the date of signature of the present Agreement in addition to, or in place of, the taxes referred to in paragraph (1).

(3) Taxes mentioned in this Article shall not include any penalty or interest imposed by either Contracting State relating to the taxes covered by this Agreement.