Double taxation relief: deduction and credit mechanisms limit domestic tax by foreign tax paid to prevent double taxation. Article 23 provides reciprocal elimination mechanisms: residents of the territory in paragraph 3(a) get a deduction from domestic tax for tax paid in the other territory, limited to the tax attributable to the income taxed abroad, and exempt income may still be taken into account when computing tax on remaining income. Residents of the territory in paragraph 3(b) receive a credit for tax paid in the other territory against domestic tax, subject to a limit equal to domestic tax on that income; dividend-related taxes on underlying profits are excluded from the credit, and exempt income may be considered in computing tax on other 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: deduction and credit mechanisms limit domestic tax by foreign tax paid to prevent double taxation.
Article 23 provides reciprocal elimination mechanisms: residents of the territory in paragraph 3(a) get a deduction from domestic tax for tax paid in the other territory, limited to the tax attributable to the income taxed abroad, and exempt income may still be taken into account when computing tax on remaining income. Residents of the territory in paragraph 3(b) receive a credit for tax paid in the other territory against domestic tax, subject to a limit equal to domestic tax on that income; dividend-related taxes on underlying profits are excluded from the credit, and exempt income may be considered in computing tax on other income.
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