Foreign tax credit and deduction mechanisms prevent double taxation by offsetting foreign tax against domestic tax liabilities. Article 23 provides reciprocal relief: Hong Kong allows a credit for Indian tax paid on India sourced income of Hong Kong residents, limited to Hong Kong tax on that income; India allows a deduction for tax paid in Hong Kong on income taxable there, limited to the portion of Indian tax attributable to that income, and may consider exempted income when calculating 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.
Foreign tax credit and deduction mechanisms prevent double taxation by offsetting foreign tax against domestic tax liabilities.
Article 23 provides reciprocal relief: Hong Kong allows a credit for Indian tax paid on India sourced income of Hong Kong residents, limited to Hong Kong tax on that income; India allows a deduction for tax paid in Hong Kong on income taxable there, limited to the portion of Indian tax attributable to that income, and may consider exempted income when calculating tax on remaining income.
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