Tax coverage under treaty: specifies covered federal and Indian income taxes and extends to substantially similar future taxes.

The Convention applies to specified United States Federal income taxes (excluding accumulated earnings, personal holding company, and social security taxes) and certain exercise taxes on insurance premiums to foreign insurers subject to a reinsurance condition, and to Indian income tax (including surcharge but excluding undistributed income tax) and surtax. Penalties or amounts payable for defaults are excluded. The Convention also covers identical or substantially similar taxes enacted later, and obliges competent authorities to notify each other of significant changes and published guidance regarding application.

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