Elimination of double taxation via foreign tax credit and deemed tax inclusion for fiscal incentives under specified sectors. Residents of one Contracting State receive a deduction for tax paid in the other State against domestic tax attributable to the income so taxed abroad; exempt income may be taken into account in computing tax on remaining income. Income of an enterprise constituting a permanent establishment in Bhutan shall be deemed to include tax forgone due to certain fiscal incentives for specified education and health projects, subject to exclusions for dividends, interest, capital gains, unrelated activities and arrangements covered by the Agreement's limitation of benefits, and limited to a prescribed initial period.
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 via foreign tax credit and deemed tax inclusion for fiscal incentives under specified sectors.
Residents of one Contracting State receive a deduction for tax paid in the other State against domestic tax attributable to the income so taxed abroad; exempt income may be taken into account in computing tax on remaining income. Income of an enterprise constituting a permanent establishment in Bhutan shall be deemed to include tax forgone due to certain fiscal incentives for specified education and health projects, subject to exclusions for dividends, interest, capital gains, unrelated activities and arrangements covered by the Agreement's limitation of benefits, and limited to a prescribed initial period.
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