(1) The existing taxes to which this Agreement shall apply are:
- (a) in India:
- (i) the income-tax (including any surcharge thereon);
- (hereinafter referred to as "Indian tax");
- (b) in South Africa:
- (i) the income-tax (the normal tax); and
- (ii) the secondary tax on companies;
- (hereinafter referred to as "South African tax").
(2) The Agreement shall apply also to any identical or substantially similar taxes which are imposed by either Contracting State 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 which have been made in their respective taxation laws.