Double taxation relief permits a tax credit limited to attributable domestic tax or exemption considered for progression. The treaty preserves domestic taxation rules unless the Agreement provides otherwise and requires that, when a resident's income may be taxed in the other State, the resident's State allow a tax credit for tax paid abroad limited to the domestic tax attributable to that income; additionally, if income is exempt under the Agreement, the resident's State may consider the exempt income in computing tax on the remaining income (exemption with progression).
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 permits a tax credit limited to attributable domestic tax or exemption considered for progression.
The treaty preserves domestic taxation rules unless the Agreement provides otherwise and requires that, when a resident's income may be taxed in the other State, the resident's State allow a tax credit for tax paid abroad limited to the domestic tax attributable to that income; additionally, if income is exempt under the Agreement, the resident's State may consider the exempt income in computing tax on the remaining income (exemption with progression).
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