Article 24 - Elimination of Double Taxation - Georgia

ARTICLE 24 ELIMINATION OF DOUBLE TAXATION 1. In India, the double taxation shall be eliminated as follows: ( a ) Where a resident of India derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in Georgia, India shall allow: ( i ) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Georgia; ( ii ) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in Georgia. Such deduction in either case shall not, however, exceed that portion of the income tax or capital tax as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital which may be taxed in Georgia. ( b ) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of India is exempt from tax in India, India may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital. 2. In Georgia, the double taxation shall be eliminated as follows: ( a ) Where a resident of Georgia derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in India, Georgia shall allow: ( i ) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in India; ( ii ) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in India. Such deduction in either case shall not, however, exceed the sums of tax, which would have accrued according to the rules and rates on this income and capital effective in Georgia. ( b ) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of a Georgia is exempt from tax in Georgia, Georgia may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital.