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Limitation of relief: tax exemptions apply only to income actually remitted to the other State, with government exception. When the Agreement exempts or reduces tax on income from sources in one Contracting State because the income is taxed in the other Contracting State by reference only to amounts remitted to or received there, the exemption or reduction in the first State applies solely to the portion of income actually remitted to or received in the other State. This limitation does not apply to income of the Government or persons approved by the competent authority of a Contracting State; 'Government' includes agencies and statutory bodies.
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.
Limitation of relief: tax exemptions apply only to income actually remitted to the other State, with government exception.
When the Agreement exempts or reduces tax on income from sources in one Contracting State because the income is taxed in the other Contracting State by reference only to amounts remitted to or received there, the exemption or reduction in the first State applies solely to the portion of income actually remitted to or received in the other State. This limitation does not apply to income of the Government or persons approved by the competent authority of a Contracting State; "Government" includes agencies and statutory bodies.
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