Double taxation relief: foreign tax credit offsets domestic tax where income is taxed abroad, subject to attributable limits and deemed taxes. Elimination of double taxation is achieved by granting a foreign tax credit: residents may deduct from domestic income tax and capital tax an amount equal to tax paid in the other Contracting State, limited to the domestic tax attributable to that income or capital. The same method applies reciprocally. Taxes foregone under tax incentive schemes designed to promote economic development are deemed payable for credit purposes. Income exempt under the Convention may be considered when calculating applicable tax rates.
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 offsets domestic tax where income is taxed abroad, subject to attributable limits and deemed taxes.
Elimination of double taxation is achieved by granting a foreign tax credit: residents may deduct from domestic income tax and capital tax an amount equal to tax paid in the other Contracting State, limited to the domestic tax attributable to that income or capital. The same method applies reciprocally. Taxes foregone under tax incentive schemes designed to promote economic development are deemed payable for credit purposes. Income exempt under the Convention may be considered when calculating applicable tax rates.
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