Foreign tax credit limits double taxation relief by capping credit to domestic tax attributable to foreign-source income. The Convention allows a resident taxed in both Contracting States to claim a foreign tax credit limited to domestic tax attributable to the foreign-source income; companies must apply such credit first against income-tax and then surtax. Romanian amounts paid by State enterprises qualify as Romanian tax. Indian tax for credit purposes includes amounts forgone under incentive-based exemptions. When a Contracting State exempts income under the Convention, it may compute tax on the taxpayer's remaining income using the rate that would have applied had the exempt income not been exempted.
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.
Foreign tax credit limits double taxation relief by capping credit to domestic tax attributable to foreign-source income.
The Convention allows a resident taxed in both Contracting States to claim a foreign tax credit limited to domestic tax attributable to the foreign-source income; companies must apply such credit first against income-tax and then surtax. Romanian amounts paid by State enterprises qualify as Romanian tax. Indian tax for credit purposes includes amounts forgone under incentive-based exemptions. When a Contracting State exempts income under the Convention, it may compute tax on the taxpayer's remaining income using the rate that would have applied had the exempt income not been exempted.
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