Elimination of double taxation: treaty provides exemption or limited tax credit for cross-border passive and business income. Article 23 provides that Hungary will generally exempt income taxed in the other Contracting State, but will allow a deduction for tax paid abroad on dividends, interest and royalties limited to the tax attributable to those items; India will allow a deduction for tax paid in Hungary limited to the part of Indian tax attributable to income taxable in Hungary; exempted income may be taken into account when 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 provides exemption or limited tax credit for cross-border passive and business income.
Article 23 provides that Hungary will generally exempt income taxed in the other Contracting State, but will allow a deduction for tax paid abroad on dividends, interest and royalties limited to the tax attributable to those items; India will allow a deduction for tax paid in Hungary limited to the part of Indian tax attributable to income taxable in Hungary; exempted income may be taken into account when computing tax on remaining income.
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