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.
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: 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.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
