Avoidance of double taxation: mutual foreign tax credit allowed up to the domestic tax attributable to that income. The Convention preserves domestic taxation except where it provides otherwise and requires mutual relief by allowing residents to deduct foreign income tax paid on income taxable in the other Contracting State, limited to the portion of domestic tax attributable to that income; the taxable amount deemed paid includes tax foregone due to development incentives, and exempt income under the Convention may be taken into account in computing the tax rate.
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.
Avoidance of double taxation: mutual foreign tax credit allowed up to the domestic tax attributable to that income.
The Convention preserves domestic taxation except where it provides otherwise and requires mutual relief by allowing residents to deduct foreign income tax paid on income taxable in the other Contracting State, limited to the portion of domestic tax attributable to that income; the taxable amount deemed paid includes tax foregone due to development incentives, and exempt income under the Convention may be taken into account in computing the tax rate.
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