Double taxation relief: treaty provides cross credit and deduction mechanisms, including deemed tax definitions and dividend credit rules. Article 24 provides that residents obtain relief by deduction or credit for tax paid in the other Contracting State, limited to the part of domestic tax attributable to that income. 'Tax paid' includes taxes forgone through reduced rates, exemptions or incentives if agreed by competent authorities. Dividends received by a company holding at least 10% of voting shares permit a credit that takes into account tax paid by the distributing company on the income out of which the dividend is paid.
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Provisions expressly mentioned in the judgment/order text.
Double taxation relief: treaty provides cross credit and deduction mechanisms, including deemed tax definitions and dividend credit rules.
Article 24 provides that residents obtain relief by deduction or credit for tax paid in the other Contracting State, limited to the part of domestic tax attributable to that income. "Tax paid" includes taxes forgone through reduced rates, exemptions or incentives if agreed by competent authorities. Dividends received by a company holding at least 10% of voting shares permit a credit that takes into account tax paid by the distributing company on the income out of which the dividend is paid.
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