Elimination of double taxation: treaty requires tax credit for foreign tax paid, limited to tax attributable to that income. The Agreement provides that each State's domestic law governs taxation except where the treaty provides otherwise and requires that residents receive a deduction from domestic income or capital tax equal to tax paid in the other Contracting State, limited to the portion of domestic tax attributable to the income or capital taxable in that other State. Taxes to be credited include amounts that would have been payable but for tax incentives, and income exempt under the Agreement may be considered for calculating the tax rate (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.
Elimination of double taxation: treaty requires tax credit for foreign tax paid, limited to tax attributable to that income.
The Agreement provides that each State's domestic law governs taxation except where the treaty provides otherwise and requires that residents receive a deduction from domestic income or capital tax equal to tax paid in the other Contracting State, limited to the portion of domestic tax attributable to the income or capital taxable in that other State. Taxes to be credited include amounts that would have been payable but for tax incentives, and income exempt under the Agreement may be considered for calculating the tax rate (progression).
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