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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 and on capital imposed on behalf of a Contracting State or of its political subdivisions or local authorities, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, 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, as well as taxes on capital appreciation.

(3) The existing taxes to which the Agreement shall apply are in particular:

  • (a) in the case of India:
    • (i) the income tax, including any surcharge thereon;
    • (ii) the wealth tax;
  • (hereinafter referred to as "Indian tax");
  • (b) in the case of Uruguay:
    • (i) the tax on business income (impuesto a las rentas de las actividades economicas-IRAE);
    • (ii) the personal income tax (impuesto a las rentas de las personas fisicas-IRPF);
    • (iii) the non-residents income tax (impuesto a las rentas de las no residents-IRNR);
    • (iv) the tax for social security assistance (impuesto de asistencia a la seguridad social-IASS); and
    • (v) the capital tax (impuesto al patrimonio-IP);
  • (hereinafter referred to as "Uruguayan 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.