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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 Convention 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) They 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 Convention shall apply are in particular:

  • (a) in the case of India:
    • (i) The income-tax, including any surcharge thereon;
  • (hereinafter referred to as "Indian tax");
  • (b) in the case of the Kingdom of Saudi Arabia:
    • (i) The Zakat;
    • (ii) The income-tax including the natural gas investment tax;
  • (hereinafter referred to as "Saudi tax").

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