Elimination of double taxation under India-Switzerland treaty: tax credit, exemption with progression and relief mechanisms. The India-Switzerland treaty eliminates double taxation by allowing India to deduct Swiss income tax paid by Indian residents on income taxable in Switzerland, capped at the portion of Indian tax attributable to that income, and by permitting Switzerland to exempt income taxable in India while applying exemption with progression. Switzerland must provide relief, on request, for dividends, interest, royalties and fees for technical services taxable in India, either by credit, lump-sum reduction, or partial exemption, and it regulates the form and procedure of such relief. A similar deduction applies for Swiss tax on capital gains from alienation of shares taxable in India.
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Provisions expressly mentioned in the judgment/order text.
Elimination of double taxation under India-Switzerland treaty: tax credit, exemption with progression and relief mechanisms.
The India-Switzerland treaty eliminates double taxation by allowing India to deduct Swiss income tax paid by Indian residents on income taxable in Switzerland, capped at the portion of Indian tax attributable to that income, and by permitting Switzerland to exempt income taxable in India while applying exemption with progression. Switzerland must provide relief, on request, for dividends, interest, royalties and fees for technical services taxable in India, either by credit, lump-sum reduction, or partial exemption, and it regulates the form and procedure of such relief. A similar deduction applies for Swiss tax on capital gains from alienation of shares taxable in India.
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