Avoidance of double taxation: reciprocal tax credit mechanism offsets foreign tax paid to prevent double taxation on cross border income. The Convention preserves domestic taxing rights except as varied by treaty and provides reciprocal tax credit mechanisms: Zambian tax paid by Indian residents on Zambia source income taxed in both States is creditable against Indian tax up to the Indian tax attributable to that income, with company surtax ordering rules; conversely, Indian tax paid by Zambian residents on India source income taxed in both States is creditable against Zambian tax up to the Zambian tax attributable to that income. Tax credits include amounts reduced or exempted under agreed economic development incentive provisions.
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.
Avoidance of double taxation: reciprocal tax credit mechanism offsets foreign tax paid to prevent double taxation on cross border income.
The Convention preserves domestic taxing rights except as varied by treaty and provides reciprocal tax credit mechanisms: Zambian tax paid by Indian residents on Zambia source income taxed in both States is creditable against Indian tax up to the Indian tax attributable to that income, with company surtax ordering rules; conversely, Indian tax paid by Zambian residents on India source income taxed in both States is creditable against Zambian tax up to the Zambian tax attributable to that income. Tax credits include amounts reduced or exempted under agreed economic development incentive provisions.
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