Double taxation relief: foreign tax credit allowed against resident tax, with exemption used for progression purposes. When a resident's income may be taxed in the other Contracting State, the resident's State shall allow as a deduction from its tax an amount equal to the income tax paid in that other State, limited to the part of domestic tax attributable to that income. Where income is exempt under the Agreement, the resident State may still take that exempted income into account when calculating tax on the remaining income (progression).
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Provisions expressly mentioned in the judgment/order text.
Double taxation relief: foreign tax credit allowed against resident tax, with exemption used for progression purposes.
When a resident's income may be taxed in the other Contracting State, the resident's State shall allow as a deduction from its tax an amount equal to the income tax paid in that other State, limited to the part of domestic tax attributable to that income. Where income is exempt under the Agreement, the resident State may still take that exempted income into account when calculating tax on the remaining income (progression).
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