Elimination of Double Taxation

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....made in this Convention. 2. (a) The amount of Mauritius tax payable, under the laws of Mauritius and in accordance with the provisions of this Convention, whether directly or by deduction, by a resident of India, in respect of profits or income arising in Mauritius, which has been subjected to tax both in India and in Mauritius, shall be allowed as a credit against the Indian tax payable in respe....

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....paragraph (a) of this paragraph] the Mauritius tax payable by the company in respect of the profits out of which such dividend is paid. 3. For the purposes of the credit referred to in paragraph (2) the term "Mauritius tax payable" shall be deemed to include any amount which would have been payable as Mauritius tax for any year but for an exemption or reduction of tax granted for that y....

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....ore allowing any such credit) is appropriate to the profits or income arising in India. (b) In the case of a dividend paid by a company which is a resident of India to a company which is a resident of Mauritius and which owns at least 10 per cent of the shares of the company paying the dividend, the credit shall take into account [in addition to any Indian tax for which credit may be allowed unde....