Tax credit for cross-border income allows domestic deduction for foreign tax paid, subject to the attributable-tax limitation. A resident State must allow a deduction from domestic income or capital tax equal to the tax paid in the other Contracting State on income or capital taxable there, limited to the portion of domestic tax attributable to that income or capital. Exempted income or capital may be taken into account when computing tax on remaining amounts. Foreign tax includes amounts reduced or waived under incentive measures, while tax paid excludes penalties or amounts payable for defaults or omissions.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Tax credit for cross-border income allows domestic deduction for foreign tax paid, subject to the attributable-tax limitation.
A resident State must allow a deduction from domestic income or capital tax equal to the tax paid in the other Contracting State on income or capital taxable there, limited to the portion of domestic tax attributable to that income or capital. Exempted income or capital may be taken into account when computing tax on remaining amounts. Foreign tax includes amounts reduced or waived under incentive measures, while tax paid excludes penalties or amounts payable for defaults or omissions.
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