Taxes on income: treaty defines scope, includes gains and preserves mining-profit taxation exception.

Article 2 establishes that the Agreement applies to taxes on income imposed by a Contracting State or its subdivisions, including taxes on total income and on elements of income such as gains from alienation, identifies the existing covered income taxes and surcharges, extends coverage to identical or substantially similar future taxes with mutual notification of significant changes, and preserves the right to tax profits of a mineral enterprise at a different effective rate.

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