Relief from double taxation: treaty provides foreign tax credit and deduction mechanisms between the United States and India.

Article 25 provides relief from double taxation by allowing U.S. residents and citizens a foreign tax credit for income taxes paid to India (including certain taxes paid by Indian distributing companies where a U.S. company holds a qualifying interest), and by allowing Indian residents a deduction for U.S. income tax paid limited to the portion of Indian tax attributable to income taxable in the United States, with surtax ordering rules for companies. The Article also sets deemed source rules for income allocation subject to domestic source rules and excludes certain categories covered by Article 12.

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