Double taxation relief: treaty provides deduction and credit methods to prevent taxing the same income in both states. Article 23 provides reciprocal relief to avoid double taxation: Canada permits deduction of Indian tax from Canadian tax, allows deduction for dividends from exempt surplus of Indian foreign affiliates, and permits deduction of capital tax paid in India; India allows credit for Canadian tax paid on Canadian-source income up to the proportionate Indian tax attributable to that income and permits deduction for capital tax paid in Canada, both subject to attribution limits. Income taxed in the other State under the Agreement is deemed to arise in that State, and specified Indian exemptions or similar future provisions may affect the tax deemed payable for deduction purposes.
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: treaty provides deduction and credit methods to prevent taxing the same income in both states.
Article 23 provides reciprocal relief to avoid double taxation: Canada permits deduction of Indian tax from Canadian tax, allows deduction for dividends from exempt surplus of Indian foreign affiliates, and permits deduction of capital tax paid in India; India allows credit for Canadian tax paid on Canadian-source income up to the proportionate Indian tax attributable to that income and permits deduction for capital tax paid in Canada, both subject to attribution limits. Income taxed in the other State under the Agreement is deemed to arise in that State, and specified Indian exemptions or similar future provisions may affect the tax deemed payable for deduction purposes.
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