Double taxation relief: tax credit deduction and exemption rules limit dual taxation by offsetting foreign tax paid. Article 23 requires that when the same income is taxable in both Contracting States the State of residence shall allow as a deduction from tax an amount equal to the tax paid in the other State, but not exceeding the portion of domestic tax attributable to that income; additionally, where income is exempt under the Agreement the State of residence may nevertheless take the exempted income into account when computing tax on the 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.
Double taxation relief: tax credit deduction and exemption rules limit dual taxation by offsetting foreign tax paid.
Article 23 requires that when the same income is taxable in both Contracting States the State of residence shall allow as a deduction from tax an amount equal to the tax paid in the other State, but not exceeding the portion of domestic tax attributable to that income; additionally, where income is exempt under the Agreement the State of residence may nevertheless take the exempted income into account when computing tax on the remaining income.
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