Double taxation relief: foreign tax credits permit crediting Kenyan or Indian tax against domestic tax subject to statutory limits. The Convention implements a foreign tax credit system: residents of one Contracting State taxed on income sourced in the other may credit the tax paid abroad against domestic tax, limited to the domestic tax attributable to that income. Special incentive provisions and agreed tax reductions or exemptions for economic development are treated as foreign tax payable for credit purposes. Companies subject to surtax receive credits against income tax first and surtax thereafter. Where income is exempt under the Convention, the residence state may calculate tax on remaining income as if the exemption did not apply.
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.
Double taxation relief: foreign tax credits permit crediting Kenyan or Indian tax against domestic tax subject to statutory limits.
The Convention implements a foreign tax credit system: residents of one Contracting State taxed on income sourced in the other may credit the tax paid abroad against domestic tax, limited to the domestic tax attributable to that income. Special incentive provisions and agreed tax reductions or exemptions for economic development are treated as foreign tax payable for credit purposes. Companies subject to surtax receive credits against income tax first and surtax thereafter. Where income is exempt under the Convention, the residence state may calculate tax on remaining income as if the exemption did not apply.
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