Double taxation relief: reciprocal limited deductions/credits permit tax paid abroad to reduce domestic tax burden under the treaty. India allows a deduction against Indian tax for tax paid in Colombia on income taxable under the Agreement, capped to the portion of Indian tax attributable to such income, and may consider exempt income when computing tax on remaining income. Colombia, within domestic limits, permits a deduction for tax paid in India limited to the part of Colombian tax attributable to income taxable in India, and for dividends allows a deduction equal to dividends multiplied by the Indian tax rate on underlying profits, adjusted if taxed in India, but not exceeding Colombian tax on those dividends.
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Provisions expressly mentioned in the judgment/order text.
Double taxation relief: reciprocal limited deductions/credits permit tax paid abroad to reduce domestic tax burden under the treaty.
India allows a deduction against Indian tax for tax paid in Colombia on income taxable under the Agreement, capped to the portion of Indian tax attributable to such income, and may consider exempt income when computing tax on remaining income. Colombia, within domestic limits, permits a deduction for tax paid in India limited to the part of Colombian tax attributable to income taxable in India, and for dividends allows a deduction equal to dividends multiplied by the Indian tax rate on underlying profits, adjusted if taxed in India, but not exceeding Colombian tax on those dividends.
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