Foreign tax credit mechanism permits crediting host country tax against domestic tax for double taxation elimination. Elimination of double taxation is effected by a foreign tax credit: residents may credit tax paid in the other Contracting State against domestic tax on the same income, subject to domestic rules and limited to the portion of domestic tax attributable to that foreign-source income. Deemed inclusion rules treat certain exempted or reduced host-country taxes as foreign tax for credit purposes, with listed domestic provisions and a mechanism for competent-authority agreement on similar future exemptions. Ceilings apply to dividends, interest and royalties and ordering rules address company surtax in India.
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.
Foreign tax credit mechanism permits crediting host country tax against domestic tax for double taxation elimination.
Elimination of double taxation is effected by a foreign tax credit: residents may credit tax paid in the other Contracting State against domestic tax on the same income, subject to domestic rules and limited to the portion of domestic tax attributable to that foreign-source income. Deemed inclusion rules treat certain exempted or reduced host-country taxes as foreign tax for credit purposes, with listed domestic provisions and a mechanism for competent-authority agreement on similar future exemptions. Ceilings apply to dividends, interest and royalties and ordering rules address company surtax in India.
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