Double taxation relief: foreign tax credit permits Indian tax to offset Australian tax on the same income. The Agreement implements a foreign tax credit regime: Indian tax paid on India-source income is creditable against Australian tax for Australian residents, including in certain dividend situations where the shareholder holds a minimum interest; specified Indian tax exemptions may be treated as tax forgone for credit purposes subject to defined categories and agreement; for Indian residents, Australian tax on Australian-source income is creditable against Indian tax limited to the proportionate Indian tax attributable to that income, with surtax credit applied after income tax.
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.
Double taxation relief: foreign tax credit permits Indian tax to offset Australian tax on the same income.
The Agreement implements a foreign tax credit regime: Indian tax paid on India-source income is creditable against Australian tax for Australian residents, including in certain dividend situations where the shareholder holds a minimum interest; specified Indian tax exemptions may be treated as tax forgone for credit purposes subject to defined categories and agreement; for Indian residents, Australian tax on Australian-source income is creditable against Indian tax limited to the proportionate Indian tax attributable to that income, with surtax credit applied after income tax.
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