Direct Tax Avoidance Agreements

UAR (Egypt)

Article II - Taxes covered - 1. This Convention shall apply to taxes on income imposed on behalf of each ContractingState or of its political sub-divisions or local authorities, where they have the authority, 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 all elements of income including taxes on gains from the sale, exchange or transfer 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,

(1)  the income-tax, including super-tax and the surcharge, imposed under the Income-tax Act, 1961 (43 of 1961), and

(2)  the surtax imposed under the Companies (Profits) Surtax Act, 1964 (7 of 1964)

(hereinafter referred to as Indian tax) ;

(b)  in the case of the United Arab Republic,

(1)  tax on income derived from immovable property (including the land tax, the buildings tax and the ghaffir tax),

(2)  tax on income from movable capital,

(3)  tax on commercial and industrial profits,

(4)  tax on wages, salaries, indemnities and pensions [as mentioned in Book III of Law (14 of 1939)],

(5)  tax on profits from liberal professions and all other non-commercial professions,

(6)  general income-tax,

(7)  defence tax (imposed on income),

(8)  national security tax (imposed on income), and

(9) supplementary taxes imposed as percentage of taxes mentioned above,

(hereinafter referred to as United Arab Republic tax).

4. The Convention shall also apply to any identical or substantially similar taxes which are subsequently imposed in addition to, or in the place of, the existing taxes.

5. At the end of each year, the competent authorities of the Contracting States shall notify to each other any significant changes which have been made in their respective taxation laws.