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let us now understand about article 2 what are the taxes which are covered for the purpose of treaty to give you a background article 2 covers what are the types of taxes to which the treaty applies it is not that the treaty applies to every types of taxes so lets say for example if you have value-added tax or vat or service tax those taxes are not covered by the treaty right what we are looking at is mainly income tax right and some treaty have provisions which apply not only to income tax but also to surcharge or says or other similar levies which are levied by a contracting state so the first question which comes up to my mind is why is article 2 even relevant there are various reasons which are important to understand why article 2 is relevant the first one is that it is only taxes which are covered under article 2 which are covered by the treaty so if a person says i have been taxed in india and i want to claim a credit for the tax that i have paid in india in u.s right he is go
