Double taxation elimination: foreign tax credited or income exempted with progression and limited treaty credit rules. Article 24 provides that India relieves double taxation by granting a deduction against Indian tax equal to tax paid in Luxembourg on income or capital taxable in Luxembourg, limited to the tax attributable to those items, and may consider exempted amounts for progression. Luxembourg, subject to its law, generally exempts income or capital taxable in India but may apply tax rates as if not exempted; for items under Articles 10, 11, 12 and 17 Luxembourg may allow a deduction equal to tax paid in India, limited to the attributable portion.
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.
Double taxation elimination: foreign tax credited or income exempted with progression and limited treaty credit rules.
Article 24 provides that India relieves double taxation by granting a deduction against Indian tax equal to tax paid in Luxembourg on income or capital taxable in Luxembourg, limited to the tax attributable to those items, and may consider exempted amounts for progression. Luxembourg, subject to its law, generally exempts income or capital taxable in India but may apply tax rates as if not exempted; for items under Articles 10, 11, 12 and 17 Luxembourg may allow a deduction equal to tax paid in India, limited to the attributable portion.
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