Elimination of double taxation: residence country credits foreign tax paid against domestic tax liability, subject to statutory limits. Double taxation is eliminated by allowing residents to deduct domestic tax by an amount equal to tax paid in the other Contracting State on income or capital taxable there, subject to limits: India caps the deduction to the portion of Indian tax attributable to that income or capital, while Georgia caps it to the tax that would have accrued under Georgian rules and rates. Where income or capital is exempt in the residence State under the Agreement, the residence State may still take the exempted amounts into account in calculating tax on the remaining income or capital.
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.
Elimination of double taxation: residence country credits foreign tax paid against domestic tax liability, subject to statutory limits.
Double taxation is eliminated by allowing residents to deduct domestic tax by an amount equal to tax paid in the other Contracting State on income or capital taxable there, subject to limits: India caps the deduction to the portion of Indian tax attributable to that income or capital, while Georgia caps it to the tax that would have accrued under Georgian rules and rates. Where income or capital is exempt in the residence State under the Agreement, the residence State may still take the exempted amounts into account in calculating tax on the remaining income or capital.
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