Double taxation relief: foreign tax credit limited to attributable domestic tax, with progression and incentive inclusion. A resident taxed in the other Contracting State may deduct income tax paid abroad up to the portion of domestic tax attributable to that foreign-taxed income; exempted income may be taken into account for computing tax on remaining income under an exemption-with-progression rule; and 'tax payable' includes taxes foregone due to domestic tax incentives intended to promote 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 relief: foreign tax credit limited to attributable domestic tax, with progression and incentive inclusion.
A resident taxed in the other Contracting State may deduct income tax paid abroad up to the portion of domestic tax attributable to that foreign-taxed income; exempted income may be taken into account for computing tax on remaining income under an exemption-with-progression rule; and "tax payable" includes taxes foregone due to domestic tax incentives intended to promote economic development.
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