Article 23 - Methods for elimination of double taxation - Estonia

ARTICLE 23 METHODS FOR ELIMINATION OF DOUBLE TAXATION Double taxation shall be eliminated as follows: 1. In India: ( a ) Where a resident of India derives income which, in accordance with the provisions of this Agreement, may be taxed in Estonia, India shall allow as a deduction from the tax on the income of that resident, an amount equal to the tax paid in Estonia. Such deduction shall not, however, exceed that portion of the tax as computed before the deduction is given, which is attributable, as the case may be, to the income which may be taxed in Estonia. ( b ) Where in accordance with any provision of the Agreement income derived by a resident of India is exempt from tax in India, India may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income. 2. In Estonia: ( a ) Where a resident of Estonia derives income which, in accordance with the provisions of this Agreement, has been taxed in India, Estonia shall, subject to the provisions of sub-paragraphs ( b ) and ( c ) exempt such income from tax. ( b ) Where a resident of Estonia derives income which in accordance with the provisions of paragraph 2 of Articles 10, 11 and 12 may be taxed in India, Estonia shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in India. Such deduction shall not, however, exceed the part of the tax, as computed before the deduction is given, which is attributable to such items of income derived from India. ( c ) Where in accordance with any provision of the Agreement income derived by a resident of Estonia is exempt from tax in Estonia, Estonia may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.