Foreign tax credit: Some interesting judicial precedents
Dr Amar Mehta Ph.D, LL.M, ACA
International Taxation Expert, Advisor, Commentator, and Author. Commentary and Database Site: Internationaltax.online
The 'elimination of double taxation' provisions in the contemporary tax treaties seem reasonably simplistic. But, in practice, they involve far more intricate issues. This article covers a few interesting Indian judicial precedents on the issue of foreign tax credit. It also contains a link for analysis of a decision of the Federal Court of Australia, wherein the Court dealt with an intriguing question: could a taxpayer (tax resident of Australia) disproportionately claim (excessive) foreign tax credit?