Double taxation relief: foreign tax credit mechanism allows cross crediting of taxes on the same income between contracting states. Article 22 provides for elimination of double taxation by allowing a foreign tax credit: Indian tax on profits, income or chargeable gains taxed in India and under the Convention is creditable against United Kingdom tax on the same items; a dividend paid to a UK resident company with substantial voting control also permits credit for Indian tax on underlying profits; reciprocal rules apply where UK tax is creditable against Indian tax subject to proportional limits and ordering rules for corporate surtaxes; exemptions and certain deductions are treated as Indian tax payable for credit purposes subject to temporal limitations; related party adjustments are allocated for credit purposes as income arising in the other State.
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Double taxation relief: foreign tax credit mechanism allows cross crediting of taxes on the same income between contracting states.
Article 22 provides for elimination of double taxation by allowing a foreign tax credit: Indian tax on profits, income or chargeable gains taxed in India and under the Convention is creditable against United Kingdom tax on the same items; a dividend paid to a UK resident company with substantial voting control also permits credit for Indian tax on underlying profits; reciprocal rules apply where UK tax is creditable against Indian tax subject to proportional limits and ordering rules for corporate surtaxes; exemptions and certain deductions are treated as Indian tax payable for credit purposes subject to temporal limitations; related party adjustments are allocated for credit purposes as income arising in the other State.
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