Elimination of double taxation: treaty-based foreign tax credit and deduction rules coordinate relief for cross-border income between two states. Article 25 requires mutual relief to avoid double taxation: India allows deductions from Indian income or capital tax for tax paid in France up to the Indian tax attributable to that income or capital, with surtax priority for companies; France grants a tax credit against French tax for Indian tax paid on income taxable in India, limited to the French tax attributable to that income, with special provisions for deemed tax paid, interest rate adjustments, dividend participation exemptions, and credit for Indian capital 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.
Elimination of double taxation: treaty-based foreign tax credit and deduction rules coordinate relief for cross-border income between two states.
Article 25 requires mutual relief to avoid double taxation: India allows deductions from Indian income or capital tax for tax paid in France up to the Indian tax attributable to that income or capital, with surtax priority for companies; France grants a tax credit against French tax for Indian tax paid on income taxable in India, limited to the French tax attributable to that income, with special provisions for deemed tax paid, interest rate adjustments, dividend participation exemptions, and credit for Indian capital tax.
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