Article 23 - Methods for elimination of double taxation - Colombia

IV. ELIMINATION OF DOUBLE TAXATION 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 Colombia, India shall allow as a deduction from the tax on the income of that resident, an amount equal to the tax paid in Colombia. 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 Colombia. (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 Colombia: (a) where a resident of Colombia derives income which, in accordance with the provisions of this Agreement may be taxed in India, Colombia shall allow, within the limitations imposed by its domestic laws: (i) the deduction from the tax on the income of that resident, an amount equal to the tax paid in India. (ii) in the case of dividends, a deduction on income tax equivalent to the total amount of the dividends multiplied by the rate of income tax in India applicable to the profits out of which such dividends are paid. When such dividends are taxed in India, such deduction will be increased by the corresponding amount. However, in no case may such deduction exceed the total amount of income tax payable in Colombia on such dividends. Such deduction shall not, however, exceed that part of the tax on the income as computed before the deduction is given, which is attributable to such items of income which may be taxed in India. (b) Where in accordance with any provision of the Agreement income derived by a resident of Colombia is exempt from tax in Colombia, Colombia may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.