Foreign tax credit: residents may offset foreign taxes against domestic tax where income is taxed in both jurisdictions. Article 25 permits residents taxed on income in the other Contracting State to claim a foreign tax credit against domestic tax limited to the domestic tax attributable to that income, with company credits applied first to income tax then surtax. The provision treats certain domestic exemptions, investment allowances, lower corporation rates and other agreed economic development incentives as deemed foreign tax payable for credit purposes, and allows exempt income under the Agreement to be considered in calculating the tax rate.
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.
Foreign tax credit: residents may offset foreign taxes against domestic tax where income is taxed in both jurisdictions.
Article 25 permits residents taxed on income in the other Contracting State to claim a foreign tax credit against domestic tax limited to the domestic tax attributable to that income, with company credits applied first to income tax then surtax. The provision treats certain domestic exemptions, investment allowances, lower corporation rates and other agreed economic development incentives as deemed foreign tax payable for credit purposes, and allows exempt income under the Agreement to be considered in calculating the tax rate.
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