Tax scope under DTAA defines covered income taxes and inclusion of future similar taxes, excluding penalties. This provision defines the Agreement's application to taxes on income imposed by a Contracting Party or its subdivisions, including taxes on total income, elements of income, gains from alienation and wages, lists existing covered taxes (profits tax, salaries tax, property tax for Hong Kong; income tax for India), extends coverage to identical or substantially similar future taxes, mandates mutual notification of significant tax-law changes, and excludes penalties, interest and fines from the terms 'Hong Kong Special Administrative Region tax' and 'Indian tax'.