Taxes on income: treaty covers income taxes, elements of income and substantially similar successor taxes between contracting states. Article 2 defines the Convention's scope as applying to taxes on income imposed on behalf of a Contracting State, covering taxes on total income and elements of income (including gains from alienation, wages-based taxes and capital appreciation). It lists existing Hungarian taxes (individual income tax, corporation tax, dividend tax) and Indian income tax (including surcharge), and extends the Convention to identical or substantially similar successor taxes, with a mutual notification obligation for substantial legislative changes.
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Provisions expressly mentioned in the judgment/order text.
Taxes on income: treaty covers income taxes, elements of income and substantially similar successor taxes between contracting states.
Article 2 defines the Convention's scope as applying to taxes on income imposed on behalf of a Contracting State, covering taxes on total income and elements of income (including gains from alienation, wages-based taxes and capital appreciation). It lists existing Hungarian taxes (individual income tax, corporation tax, dividend tax) and Indian income tax (including surcharge), and extends the Convention to identical or substantially similar successor taxes, with a mutual notification obligation for substantial legislative changes.
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