Double taxation relief: bilateral tax credit and exemption-with-progression mechanisms limit domestic tax to attributable income. Article 23 establishes bilateral relief for double taxation by confirming domestic law subject to the Agreement and prescribing reciprocal mechanisms: each Contracting State shall allow a deduction from resident tax equal to tax paid in the other State, limited to the portion of domestic tax attributable to income taxable abroad; each State may also take into account income exempt under the Agreement when calculating tax on the resident's remaining income.
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 relief: bilateral tax credit and exemption-with-progression mechanisms limit domestic tax to attributable income.
Article 23 establishes bilateral relief for double taxation by confirming domestic law subject to the Agreement and prescribing reciprocal mechanisms: each Contracting State shall allow a deduction from resident tax equal to tax paid in the other State, limited to the portion of domestic tax attributable to income taxable abroad; each State may also take into account income exempt under the Agreement when calculating tax on the resident's remaining income.
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