Elimination of double taxation: tax credit and deduction rules align relief for cross-border income between Contracting States. The Convention preserves domestic taxing laws but provides relief from double taxation: India allows deductions from Indian tax for Japanese tax paid on income taxable in Japan, limited to the portion of Indian tax attributable to that income and applied first against income-tax and then surtax for companies. Japan permits a credit against Japanese tax for Indian tax paid on income taxable in India, limited to the portion of Japanese tax attributable to that income, with special consideration for dividends received by Japanese resident companies holding a substantial share in Indian companies. A prior deemed-payment provision related to Indian tax incentives has been omitted.
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: tax credit and deduction rules align relief for cross-border income between Contracting States.
The Convention preserves domestic taxing laws but provides relief from double taxation: India allows deductions from Indian tax for Japanese tax paid on income taxable in Japan, limited to the portion of Indian tax attributable to that income and applied first against income-tax and then surtax for companies. Japan permits a credit against Japanese tax for Indian tax paid on income taxable in India, limited to the portion of Japanese tax attributable to that income, with special consideration for dividends received by Japanese resident companies holding a substantial share in Indian companies. A prior deemed-payment provision related to Indian tax incentives has been omitted.
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