Exemption method for double taxation: residence state exempts foreign taxable income while limited credits apply for certain items. Article 23A establishes the Exemption Method, under which the resident state generally exempts income or capital taxable in the other Contracting State, subject to exceptions. For specified income categories the residence state may instead allow a deduction or credit for tax paid abroad, limited to the portion of residence tax attributable to that income. The residence state may also consider exempted income when computing tax on the remaining base, and paragraph 4 excludes cases where the other state applies comparable exemption or limited-relief rules.
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.
Exemption method for double taxation: residence state exempts foreign taxable income while limited credits apply for certain items.
Article 23A establishes the Exemption Method, under which the resident state generally exempts income or capital taxable in the other Contracting State, subject to exceptions. For specified income categories the residence state may instead allow a deduction or credit for tax paid abroad, limited to the portion of residence tax attributable to that income. The residence state may also consider exempted income when computing tax on the remaining base, and paragraph 4 excludes cases where the other state applies comparable exemption or limited-relief rules.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
