Double taxation relief: treaty credit and exemption rules coordinate cross border income taxation to prevent double taxation under treaty terms. Elimination of double taxation is achieved by credit and exemption mechanisms: residents of India receive a tax credit for foreign income-tax and foreign net-wealth tax paid, limited to the Indian tax attributable to that income or assets, and may have foreign-only taxable income considered for graduated rates. The other Contracting State grants credit for Indian tax under its domestic rules, may consider India only taxable income for rate determination, exempts certain intercompany dividends under its law, and treats specified incentive-related tax reductions as deemed tax paid for credit purposes during a transitional period extendable by mutual agreement.
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: treaty credit and exemption rules coordinate cross border income taxation to prevent double taxation under treaty terms.
Elimination of double taxation is achieved by credit and exemption mechanisms: residents of India receive a tax credit for foreign income-tax and foreign net-wealth tax paid, limited to the Indian tax attributable to that income or assets, and may have foreign-only taxable income considered for graduated rates. The other Contracting State grants credit for Indian tax under its domestic rules, may consider India only taxable income for rate determination, exempts certain intercompany dividends under its law, and treats specified incentive-related tax reductions as deemed tax paid for credit purposes during a transitional period extendable by mutual agreement.
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