Double taxation elimination: treaty tax credit limits domestic relief to tax attributable to treaty taxed income. The treaty preserves domestic taxation except where overridden and requires relief for double taxation by allowing residents to deduct as a credit the income tax paid in the other Contracting State; such deductions are limited to the portion of domestic tax attributable to income taxable in the other State. The taxable amount is deemed to include taxes that would have been payable absent domestic tax incentives promoting economic development.
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 elimination: treaty tax credit limits domestic relief to tax attributable to treaty taxed income.
The treaty preserves domestic taxation except where overridden and requires relief for double taxation by allowing residents to deduct as a credit the income tax paid in the other Contracting State; such deductions are limited to the portion of domestic tax attributable to income taxable in the other State. The taxable amount is deemed to include taxes that would have been payable absent domestic tax incentives promoting economic development.
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