Elimination of double taxation: limited tax credit for foreign tax paid, with exemption considered for progression in tax computation. Elimination of double taxation is effected by allowing a resident State to deduct from the resident's domestic tax an amount equal to income tax paid in the other Contracting State on income taxable there, subject to an attributable income limitation that caps the deduction at the part of domestic tax attributable to that income; where income is exempt under the Agreement, the resident State may nonetheless take that exempted income into account 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.
Elimination of double taxation: limited tax credit for foreign tax paid, with exemption considered for progression in tax computation.
Elimination of double taxation is effected by allowing a resident State to deduct from the resident's domestic tax an amount equal to income tax paid in the other Contracting State on income taxable there, subject to an attributable income limitation that caps the deduction at the part of domestic tax attributable to that income; where income is exempt under the Agreement, the resident State may nonetheless take that exempted income into account in computing tax on the remaining income (exemption with progression).
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