Elimination of double taxation: treaty requires exemption or tax credit to prevent double taxation on cross border income and capital. Article 23 provides reciprocal mechanisms to eliminate double taxation: the Netherlands may exempt or reduce tax on items taxable in India or allow a deduction equal to Indian tax paid subject to Netherlands limitations, including a ten year transitional treatment of reduced Indian tax on interest under investment incentives. India allows deduction for Netherlands income or capital tax to the extent attributable to income or capital taxed in the Netherlands, with company surtax credits applied in sequence and certain Netherlands investment account items excluded from credit calculations.
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: treaty requires exemption or tax credit to prevent double taxation on cross border income and capital.
Article 23 provides reciprocal mechanisms to eliminate double taxation: the Netherlands may exempt or reduce tax on items taxable in India or allow a deduction equal to Indian tax paid subject to Netherlands limitations, including a ten year transitional treatment of reduced Indian tax on interest under investment incentives. India allows deduction for Netherlands income or capital tax to the extent attributable to income or capital taxed in the Netherlands, with company surtax credits applied in sequence and certain Netherlands investment account items excluded from credit calculations.
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