Elimination of double taxation: treaty provides foreign tax credit and exemption-with-progression to relieve cross border income taxation. The treaty eliminates double taxation by reciprocal relief: India allows a foreign tax credit for tax paid in Malta limited to the portion of Indian tax attributable to Malta-taxable income and may apply exemption-with-progression when income is treaty-exempt; Malta allows a credit for Indian tax against Malta tax subject to Malta's domestic foreign tax credit rules and may also apply exemption-with-progression for treaty-exempt 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: treaty provides foreign tax credit and exemption-with-progression to relieve cross border income taxation.
The treaty eliminates double taxation by reciprocal relief: India allows a foreign tax credit for tax paid in Malta limited to the portion of Indian tax attributable to Malta-taxable income and may apply exemption-with-progression when income is treaty-exempt; Malta allows a credit for Indian tax against Malta tax subject to Malta's domestic foreign tax credit rules and may also apply exemption-with-progression for treaty-exempt income.
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