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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.

ARTICLE 2

Taxes Covered

(1) This Agreement shall apply to taxes on income imposed on behalf of a Contracting State, of its administrative-territorial units, political sub-divisions or of its 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 Romania:
    • (i) the tax on income;
    • (ii) the tax on profit;
  • (hereinafter referred to as "Romanian tax");
  • (b) in the case of India:
    • (i) the income tax;
  • including any surcharge thereon;
  • (hereinafter referred to as "Indian tax").

(4) The Agreement shall apply also to any identical or substantially similar taxes that are imposed after the date of signature of this Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any substantial changes that have been made in their respective taxation laws.