Elimination of Double Taxation

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....ere express provision to the contrary is made in this Agreement. 2. In the case of India, double taxation shall be avoided as follows: (a) Where a resident of India derives income which, in accordance with the provisions of the Agreement, may be taxed in Belgium, India shall allow as a deduction from the tax on the income of that resident an amount equal to the income tax paid in Belgi....

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....to the income derived from Belgium. 3. In the case of Belgium, double taxation shall be avoided as follows: (a) Where a resident of Belgium derives income which may be taxed in India in accordance with the provisions of the Agreement, other than those of paragraph 2 of Article 10, of paragraphs 2 and 6 of Article 11 and of paragraphs 2 and 6 of Article 12, Belgium shall exempt such inc....

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.... abroad. (ii) Where a resident of Belgium derives fees for technical services which have been taxed in India in accordance with paragraphs 2 or 6 of Article 12, the provisions of Belgian tax law with respect to earned income derived from sources outside Belgium and subject to foreign tax shall apply. (c) Where a company which is a resident of Belgium owns shares in a company whic....

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.... said losses. (e) For the purposes of sub-paragraph (b)(i) the term "Indian tax levied" shall be deemed to include any amount which would have been payable as Indian tax under the laws of India and in accordance with the provisions of the Agreement for any year but for a deduction allowed in computing the taxable income or an exemption from or a reduction of tax granted for that year unde....