Direct Tax Avoidance Agreements

                                                                                                      Taipei

Article 2

TAXES COVERED

1. This Agreement shall apply to taxes on income imposed on behalf of each territory or of its sub-divisions or 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 territory in which the taxation law administered by the Ministry of Finance of India is applied : the income-tax, including any surcharge thereon;

 (b)  in the territory in which the taxation law administered by the Ministry of Finance in Taipei is applied :

  (i)  the profit seeking enterprise income-tax;

 (ii)  the individual consolidated income-tax; and

(iii)  the income basic tax, including the supplements levied thereon.

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 territories shall notify each other of any significant changes that have been made in their respective taxation laws.