Limitation of relief: treaty tax relief applies only to income remitted to or received in the other State. Article 24 limits treaty exemption or reduced tax in the source State to the portion of income remitted to or received in the other State when that other State taxes by reference to remitted amounts rather than the full amount. An exception preserves relief for income of the Government or persons approved by the competent authority, with 'Government' including agencies and statutory bodies.
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.
Limitation of relief: treaty tax relief applies only to income remitted to or received in the other State.
Article 24 limits treaty exemption or reduced tax in the source State to the portion of income remitted to or received in the other State when that other State taxes by reference to remitted amounts rather than the full amount. An exception preserves relief for income of the Government or persons approved by the competent authority, with "Government" including agencies and statutory bodies.
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