Elimination of double taxation: tax credit allowed for foreign taxes paid, subject to domestic limitation and exclusions. Elimination of double taxation is achieved by allowing a resident State to deduct from domestic income or capital tax an amount equal to tax paid in the other Contracting State, limited to the domestic tax attributable to that income or capital. Exempted items may be taken into account for computing tax on remaining items. Taxes reduced or waived under the other State's incentive provisions are deemed tax paid for credit purposes, while amounts payable as penalties or for default are excluded from 'tax paid.'
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: tax credit allowed for foreign taxes paid, subject to domestic limitation and exclusions.
Elimination of double taxation is achieved by allowing a resident State to deduct from domestic income or capital tax an amount equal to tax paid in the other Contracting State, limited to the domestic tax attributable to that income or capital. Exempted items may be taken into account for computing tax on remaining items. Taxes reduced or waived under the other State's incentive provisions are deemed tax paid for credit purposes, while amounts payable as penalties or for default are excluded from "tax paid."
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