Elimination of double taxation: foreign tax credit permits crediting foreign taxes against domestic tax liability for same income. A foreign tax credit mechanism permits taxes paid in the other Contracting State to be credited against domestic tax on the same profits, income or chargeable gains. UK residents may credit Indian tax on Indian-source income (with special additional credit for certain dividends reflecting tax paid by the Indian company). Reciprocal credit rules apply to Indian residents for UK-source income, subject to a proportional limitation and ordering where surtax applies.
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Provisions expressly mentioned in the judgment/order text.
Elimination of double taxation: foreign tax credit permits crediting foreign taxes against domestic tax liability for same income.
A foreign tax credit mechanism permits taxes paid in the other Contracting State to be credited against domestic tax on the same profits, income or chargeable gains. UK residents may credit Indian tax on Indian-source income (with special additional credit for certain dividends reflecting tax paid by the Indian company). Reciprocal credit rules apply to Indian residents for UK-source income, subject to a proportional limitation and ordering where surtax applies.
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