Elimination of double taxation: credit and exemption mechanisms determine tax relief between residents of India and Luxembourg. The treaty prescribes reciprocal relief: India grants a tax credit for Luxembourg tax paid, limited to the tax attributable to income or capital taxable in Luxembourg, and may apply exemption with progression. Luxembourg generally exempts income or capital taxable in India but may compute tax on remaining income as if the exempt amounts were included; for specified income categories Luxembourg grants a tax credit for Indian tax paid, limited to the tax attributable to that income, with exclusions where India grants treaty exemptions.
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: credit and exemption mechanisms determine tax relief between residents of India and Luxembourg.
The treaty prescribes reciprocal relief: India grants a tax credit for Luxembourg tax paid, limited to the tax attributable to income or capital taxable in Luxembourg, and may apply exemption with progression. Luxembourg generally exempts income or capital taxable in India but may compute tax on remaining income as if the exempt amounts were included; for specified income categories Luxembourg grants a tax credit for Indian tax paid, limited to the tax attributable to that income, with exclusions where India grants treaty exemptions.
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