Double taxation relief: foreign tax credit allowed against domestic tax where income is taxed in both states. Article 22 provides that when the same income is taxable in both Contracting States relief is supplied by allowing a foreign tax credit: tax paid in the source State on income from that State shall be credited against tax computed in the residence State on the same income, subject to domestic rules on credit allowance and limits appropriate to such income. Special tax incentives or statutory exemptions may be deemed part of payable tax for credit purposes if agreed by competent authorities, and a State may compute tax on remaining income as if exempted income were not exempt.
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 credit allowed against domestic tax where income is taxed in both states.
Article 22 provides that when the same income is taxable in both Contracting States relief is supplied by allowing a foreign tax credit: tax paid in the source State on income from that State shall be credited against tax computed in the residence State on the same income, subject to domestic rules on credit allowance and limits appropriate to such income. Special tax incentives or statutory exemptions may be deemed part of payable tax for credit purposes if agreed by competent authorities, and a State may compute tax on remaining income as if exempted income were not exempt.
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