Double tax elimination: India credits Belgian tax on Belgian taxable income; Belgium exempts or credits corresponding income. Elimination of double taxation is achieved by India granting a deduction (foreign tax credit) for Belgian tax on income taxable in Belgium, limited to the Indian tax attributable to that income and applied first against income tax and then surtax for companies; Belgium generally exempts income taxable in India but may apply exemption with progression, and provides credit or specific treatment for dividends, interest, royalties and technical service fees, with rules addressing corporate participation relief and interaction with loss relief.
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Provisions expressly mentioned in the judgment/order text.
Double tax elimination: India credits Belgian tax on Belgian taxable income; Belgium exempts or credits corresponding income.
Elimination of double taxation is achieved by India granting a deduction (foreign tax credit) for Belgian tax on income taxable in Belgium, limited to the Indian tax attributable to that income and applied first against income tax and then surtax for companies; Belgium generally exempts income taxable in India but may apply exemption with progression, and provides credit or specific treatment for dividends, interest, royalties and technical service fees, with rules addressing corporate participation relief and interaction with loss relief.
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