Article 23 - Elimination of double taxation

Double taxation elimination: foreign tax credit limited to domestic tax attributable to foreign-source income ensures relief.

A credit is allowed for tax paid in the other Contracting State against domestic tax on the same profits or income, limited to the domestic tax attributable to that foreign-source income. For Indian residents, Indonesian tax on Indonesian-source income taxed in both States is creditable against Indian tax, with company surtax relief applied after ordinary income tax. For Indonesian residents, Indian tax on Indian-source income taxed in both States is creditable against Indonesian tax subject to the same limitation. Deemed 'tax payable' includes amounts forgone due to domestic special incentive measures and mutually agreed incentives for computing credits.