Taxes on income and capital are covered by the treaty, including specified national taxes and substantially similar future taxes. Article 2 provides that the Convention applies to taxes on income and on capital irrespective of manner of levy, including taxes on total income or capital and elements thereof (such as gains from alienation, wages-based taxes and capital appreciation). It names the existing Spanish and Indian taxes covered and extends application to identical or substantially similar taxes enacted after signature, with a requirement that competent authorities notify each other of significant tax law changes.
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Provisions expressly mentioned in the judgment/order text.
Taxes on income and capital are covered by the treaty, including specified national taxes and substantially similar future taxes.
Article 2 provides that the Convention applies to taxes on income and on capital irrespective of manner of levy, including taxes on total income or capital and elements thereof (such as gains from alienation, wages-based taxes and capital appreciation). It names the existing Spanish and Indian taxes covered and extends application to identical or substantially similar taxes enacted after signature, with a requirement that competent authorities notify each other of significant tax law changes.
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