Elimination of double taxation: foreign tax credit and exemption rules determine relief for cross-border income and capital. The Agreement preserves domestic taxing powers while providing treaty relief to prevent double taxation between Canada and India. Canada grants deductions for Indian tax on income, deductions for dividends from an Indian affiliate's exempt surplus, credits for capital tax paid in India and permits consideration of exempt income when computing tax on remaining income. India allows a credit for Canadian tax paid on Canadian-source income limited to the proportion of Indian tax attributable to that income and permits deduction for capital tax paid in Canada to the extent attributable to capital taxable in Canada.
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: foreign tax credit and exemption rules determine relief for cross-border income and capital.
The Agreement preserves domestic taxing powers while providing treaty relief to prevent double taxation between Canada and India. Canada grants deductions for Indian tax on income, deductions for dividends from an Indian affiliate's exempt surplus, credits for capital tax paid in India and permits consideration of exempt income when computing tax on remaining income. India allows a credit for Canadian tax paid on Canadian-source income limited to the proportion of Indian tax attributable to that income and permits deduction for capital tax paid in Canada to the extent attributable to capital taxable in Canada.
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