Elimination of double taxation: foreign tax paid may be credited or deducted to avoid double taxation under the treaty. Relief from double taxation is provided by allowing a credit in Israel for Indian tax paid on Indian-source income or capital, limited to the portion of Israeli tax attributable to that income or capital; India allows deductions for tax paid in Israel against Indian income tax and capital tax, each limited to the part attributable to income or capital taxable in Israel. Exempted income or capital may still be taken into account when computing tax on remaining items. Certain prior percentage-based credit provisions have been omitted.
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Provisions expressly mentioned in the judgment/order text.
Elimination of double taxation: foreign tax paid may be credited or deducted to avoid double taxation under the treaty.
Relief from double taxation is provided by allowing a credit in Israel for Indian tax paid on Indian-source income or capital, limited to the portion of Israeli tax attributable to that income or capital; India allows deductions for tax paid in Israel against Indian income tax and capital tax, each limited to the part attributable to income or capital taxable in Israel. Exempted income or capital may still be taken into account when computing tax on remaining items. Certain prior percentage-based credit provisions have been omitted.
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