Avoidance of double taxation: treaty provides reciprocal tax credits and deductions to prevent income from being taxed twice under domestic rules. Article 25 provides reciprocal relief to avoid double taxation: India allows a deduction against Indian tax for Singapore tax paid on income taxable under the Agreement, including deemed Singapore tax arising from specified reliefs, with a cap tied to the Indian tax attributable to that income; a special dividend rule applies where an Indian resident holds not less than 25 per cent of the Singapore payor. Singapore, subject to its laws on foreign tax credits, allows a credit for Indian tax paid, similarly recognising certain Indian reliefs as constituting Indian tax paid, and income exempt under the Agreement may be taken into account in computing tax rates.
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.
Avoidance of double taxation: treaty provides reciprocal tax credits and deductions to prevent income from being taxed twice under domestic rules.
Article 25 provides reciprocal relief to avoid double taxation: India allows a deduction against Indian tax for Singapore tax paid on income taxable under the Agreement, including deemed Singapore tax arising from specified reliefs, with a cap tied to the Indian tax attributable to that income; a special dividend rule applies where an Indian resident holds not less than 25 per cent of the Singapore payor. Singapore, subject to its laws on foreign tax credits, allows a credit for Indian tax paid, similarly recognising certain Indian reliefs as constituting Indian tax paid, and income exempt under the Agreement may be taken into account in computing tax rates.
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