Elimination of Double Taxation

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..... e allowance as a credit against Indian tax of tax paid in a territory outside India (which shall not affect the general principle hereof), the amount of Irish tax paid, under the laws of Ireland and in accordance with the provisions of this Convention, whether directly or by deduction, by a resident of India, in respect of income from sources within Ireland which has been subjected to tax both in .....

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..... e to the same profits, income and gains by reference to which Indian tax is computed. (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 Ireland and which controls directly or indirectly 25 per cent or more of the voting power in the company paying the dividend, the credit shall take into account [in addition to any Indian tax creditabl .....

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..... ce the date of signature of this Convention and that the activities have been carried out within India. (b) The provisions of sub-paragraph (a) shall cease to apply after twelve years from the date of entry into force of this Convention. (c) Should India amend in substance its incentive provisions in relation to the activities specified in sub-paragraph (a) or introduce any new incentive provision .....

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