Elimination of double taxation: treaty allows resident tax credit for foreign taxes paid to avoid double taxation. Relief from double taxation is provided by allowing residents a deduction from domestic tax equal to tax paid in the other Contracting State, limited to the portion of domestic tax attributable to the income or capital taxable abroad; this applies reciprocally and treats deemed foreign tax as including taxes after domestic tax incentives, while exempted income may still be considered in computing 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.
Elimination of double taxation: treaty allows resident tax credit for foreign taxes paid to avoid double taxation.
Relief from double taxation is provided by allowing residents a deduction from domestic tax equal to tax paid in the other Contracting State, limited to the portion of domestic tax attributable to the income or capital taxable abroad; this applies reciprocally and treats deemed foreign tax as including taxes after domestic tax incentives, while exempted income may still be considered in computing tax on remaining income.
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