Avoidance of double taxation preserves foreign tax credits to prevent overlapping taxation of the same income across jurisdictions. Residents taxed on income or capital that may be taxed in the other Contracting State are entitled to relief by way of credit: India grants a deduction from Indian tax for tax paid in Cyprus up to the portion attributable to such income or capital; Cyprus allows a credit for Indian tax subject to its domestic law limited to tax appropriate to Indian-source income. The Article treats incentive-reduced tax as included for credit purposes and prescribes deemed rates for dividends, interest, royalties and technical fees. Exempt income may be taken into account for progression.
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 preserves foreign tax credits to prevent overlapping taxation of the same income across jurisdictions.
Residents taxed on income or capital that may be taxed in the other Contracting State are entitled to relief by way of credit: India grants a deduction from Indian tax for tax paid in Cyprus up to the portion attributable to such income or capital; Cyprus allows a credit for Indian tax subject to its domestic law limited to tax appropriate to Indian-source income. The Article treats incentive-reduced tax as included for credit purposes and prescribes deemed rates for dividends, interest, royalties and technical fees. Exempt income may be taken into account for progression.
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