Double taxation relief: foreign tax credit and deduction mechanisms permit cross-border tax relief between contracting jurisdictions. Article 23 establishes reciprocal relief: India allows a deduction for tax paid in Malta limited to the portion of Indian tax attributable to Malta-taxable income and may factor exempted income into taxation of remaining income; Malta, subject to domestic law, allows Indian tax as a credit against Malta tax on income sourced in India and may likewise take exempted income into account when computing tax on remaining 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: foreign tax credit and deduction mechanisms permit cross-border tax relief between contracting jurisdictions.
Article 23 establishes reciprocal relief: India allows a deduction for tax paid in Malta limited to the portion of Indian tax attributable to Malta-taxable income and may factor exempted income into taxation of remaining income; Malta, subject to domestic law, allows Indian tax as a credit against Malta tax on income sourced in India and may likewise take exempted income into account when computing tax on remaining income.
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