(1) This Agreement shall apply to taxes on income imposed on behalf of a Contracting State or of its political sub-divisions 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 India:
- (i) the income tax, including any surcharge thereon;
- (hereinafter referred to as "Indian tax");
- (b) in Mozambique:
- (i) Personal Income-tax (Imposto sobre o Rendimento das Pessoas Singulares-IRPS); and
- (ii) Corporate Income-tax (Imposto sobre o Rendimento das Pessoas Colectivas-IRPC)
- (hereinafter referred to as " Mozambican tax").
(4) The Agreement shall apply also 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.