Double taxation relief: foreign tax credit allowed, limited to tax attributable to income, with progression retained. Article 25 provides that domestic law governs taxation except where the Agreement applies; each Contracting State shall allow a deduction (foreign tax credit) for income-tax paid in the other State, limited to the part of domestic tax attributable to the income taxed abroad, and income exempt under the Agreement may be considered in calculating the tax rate for other taxable income (progression).
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Provisions expressly mentioned in the judgment/order text.
Double taxation relief: foreign tax credit allowed, limited to tax attributable to income, with progression retained.
Article 25 provides that domestic law governs taxation except where the Agreement applies; each Contracting State shall allow a deduction (foreign tax credit) for income-tax paid in the other State, limited to the part of domestic tax attributable to the income taxed abroad, and income exempt under the Agreement may be considered in calculating the tax rate for other taxable income (progression).
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