Elimination of double taxation: foreign tax credit allowed under treaty, limited by the domestic tax attributable to the income. The treaty requires that domestic tax systems permit a deduction or credit for foreign tax paid on income taxable in the treaty partner, limited by a cap tied to the portion of domestic tax attributable to that income. A resident may deduct foreign tax paid, whether direct or by deduction, but not more than the part of domestic tax attributable to the income; reciprocally, the partner jurisdiction limits deduction to the proportion of domestic tax that corresponds to the income concerned.
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: foreign tax credit allowed under treaty, limited by the domestic tax attributable to the income.
The treaty requires that domestic tax systems permit a deduction or credit for foreign tax paid on income taxable in the treaty partner, limited by a cap tied to the portion of domestic tax attributable to that income. A resident may deduct foreign tax paid, whether direct or by deduction, but not more than the part of domestic tax attributable to the income; reciprocally, the partner jurisdiction limits deduction to the proportion of domestic tax that corresponds to the income concerned.
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