Tax credit for foreign tax: limited credit and exemption-with-progression prevent double taxation on cross-border income. Article 23 provides reciprocal limited tax credit relief: each Contracting State allows as a deduction from domestic tax an amount equal to income tax paid in the other State, limited to the portion of domestic tax attributable to the income so taxed abroad. Additionally, where income is exempt in the State of residence under the Convention, that exempt income may be taken into account in computing tax on the resident's remaining income (exemption with progression).
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.
Tax credit for foreign tax: limited credit and exemption-with-progression prevent double taxation on cross-border income.
Article 23 provides reciprocal limited tax credit relief: each Contracting State allows as a deduction from domestic tax an amount equal to income tax paid in the other State, limited to the portion of domestic tax attributable to the income so taxed abroad. Additionally, where income is exempt in the State of residence under the Convention, that exempt income may be taken into account in computing tax on the resident's remaining income (exemption with progression).
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