Methods for elimination of double taxation: three Options set alternative tax reliefs and notification rules under tax treaties. Article 5 allows a Party to choose Option A, B or C (or none) to address elimination of double taxation where treaty provisions would otherwise exempt income or capital. Option A denies exemption when the other Contracting Jurisdiction exempts or limits tax and provides a deduction equal to tax paid abroad, capped by the tax attributable to that item. Option B addresses dividend treatment that gives rise to a deduction abroad and permits a similar capped deduction. Option C permits a deduction for income or capital tax paid abroad and allows exempted items to be taken into account in computing tax on remaining income. Parties may reserve application to specific Covered Tax Agreements and must notify the Depositary of identified provisions.
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Methods for elimination of double taxation: three Options set alternative tax reliefs and notification rules under tax treaties.
Article 5 allows a Party to choose Option A, B or C (or none) to address elimination of double taxation where treaty provisions would otherwise exempt income or capital. Option A denies exemption when the other Contracting Jurisdiction exempts or limits tax and provides a deduction equal to tax paid abroad, capped by the tax attributable to that item. Option B addresses dividend treatment that gives rise to a deduction abroad and permits a similar capped deduction. Option C permits a deduction for income or capital tax paid abroad and allows exempted items to be taken into account in computing tax on remaining income. Parties may reserve application to specific Covered Tax Agreements and must notify the Depositary of identified provisions.
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