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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 are to taxes of income imposed on behalf of each Contracting State, irrespective of 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 taxes to which this Convention shall apply are:

  • (a) in India:
    • (i) the income-tax including any surcharge thereon imposed under the Income-tax Act, 1961 (43 of 961);
    • (ii) the surtax imposed under the Companies (Profits) Surtax Act, 1964 (7 of 1964);
  • (hereafter referred to as "Indian tax");
  • (b) in the Philippines:
    • (i) the income-taxes imposed by the Government of the Republic of the Philippines ;
  • (hereafter to as "Philippine tax").

(4) The Convention 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 Convention in addition to, or in place of the taxes referred to in paragraph 1. The competent authorities of the Contracting State shall notify each other of any sub-stantial changes which are made in their respective taxation laws.