Elimination of double taxation: tax paid abroad may be deducted or credited to prevent double taxation under the treaty. Article 23 requires elimination of double taxation: India permits a deduction for tax paid in Korea limited to the portion attributable to income taxable in India and may apply exemption with progression; Korea, subject to domestic law, allows Indian tax on Indian-source income (excluding tax on profits underlying dividends) as a credit against Korean tax, limited to the proportion of Korean tax attributable to that Indian-source 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: tax paid abroad may be deducted or credited to prevent double taxation under the treaty.
Article 23 requires elimination of double taxation: India permits a deduction for tax paid in Korea limited to the portion attributable to income taxable in India and may apply exemption with progression; Korea, subject to domestic law, allows Indian tax on Indian-source income (excluding tax on profits underlying dividends) as a credit against Korean tax, limited to the proportion of Korean tax attributable to that Indian-source income.
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