Partnership taxation: deletion of treaty provision preserving UK taxation of resident partners and partner-level tax credits. Article 25 (Partnerships) of the India-United Kingdom DTAA was deleted. The deleted provision had two primary rules: the UK could tax a UK-resident partner on his share of partnership income and gains despite a partnership-level exemption, with such income treated as sourced in India for Article 24 purposes; and a partnership resident in India could not claim a tax credit under Article 11 for UK dividends, although an individual Indian-resident partner could claim the credit for his share of those dividends.
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.
Partnership taxation: deletion of treaty provision preserving UK taxation of resident partners and partner-level tax credits.
Article 25 (Partnerships) of the India-United Kingdom DTAA was deleted. The deleted provision had two primary rules: the UK could tax a UK-resident partner on his share of partnership income and gains despite a partnership-level exemption, with such income treated as sourced in India for Article 24 purposes; and a partnership resident in India could not claim a tax credit under Article 11 for UK dividends, although an individual Indian-resident partner could claim the credit for his share of those dividends.
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