Elimination of double taxation: treaty-based foreign tax credit and dividend credit rules prevent double taxation on cross-border income. Article 24 provides for elimination of double taxation by a credit method: UK residents may credit Indian tax on India source profits, income and gains against UK tax on the same items, with a special rule allowing inclusion of Indian corporate tax on profits underlying dividends when a UK resident company holds at least 10% voting power. Indian residents may credit UK tax on UK source income against Indian tax pro rata to that income, with company surtax credits applied after income tax. 'Indian tax payable' is deemed to include amounts forgone by specified deductions or exemptions under the Income tax Act, subject to a ten fiscal year limitation.
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.
Elimination of double taxation: treaty-based foreign tax credit and dividend credit rules prevent double taxation on cross-border income.
Article 24 provides for elimination of double taxation by a credit method: UK residents may credit Indian tax on India source profits, income and gains against UK tax on the same items, with a special rule allowing inclusion of Indian corporate tax on profits underlying dividends when a UK resident company holds at least 10% voting power. Indian residents may credit UK tax on UK source income against Indian tax pro rata to that income, with company surtax credits applied after income tax. "Indian tax payable" is deemed to include amounts forgone by specified deductions or exemptions under the Income tax Act, subject to a ten fiscal year limitation.
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