Article 23 - Elimination of Double Taxation

Elimination of double taxation: bilateral tax credit mechanism permits offset of foreign tax against domestic tax on cross-border income.

Elimination of double taxation is achieved by a bilateral tax credit system: residents may credit tax paid in the other Contracting State against domestic tax on income taxed in both States, with credits limited by the proportion of domestic tax attributable to that income. Reciprocal rules apply for Indian tax creditable in Ireland, including additional credit treatment for dividends paid to qualifying Irish corporate shareholders that reflect Indian tax paid by the distributing company. Specified Indian incentive exemptions may be partially deemed as Indian tax payable for dividend credit purposes, subject to time limits and negotiation if incentives change.