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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 24

Elimination of Double Taxation

It is agreed that double taxation shall be avoided in accordance with the following paragraphs of this Article:

(1) In the case of the Islamic Republic of Iran:

  • (a) Where a resident of the Islamic Republic of Iran derives income, which, in accordance with the provisions of this Agreement, may be taxed in India, the Islamic Republic of Iran shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in India.
  • Such deduction shall not, however, exceed that portion of the tax, as computed before the deduction is given, which is attributable, to that income which may be taxed in India.
  • (b) Where, in accordance with any provision of the Agreement income derived by a resident of the Islamic Republic of Iran is exempt from tax in India, the Islamic Republic of Iran may, notwithstanding the exemption, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.

(2) In the case of India:

  • (a) Where a resident of India derives income which, in accordance with the provisions of this Agreement, may be taxed in the Islamic Republic of Iran, India shall allow as a deduction from the tax on the income of that resident, an amount equal to the tax paid in the Islamic Republic of Iran.
  • Such deduction shall not, however, exceed that portion of the tax as computed before the deduction is given, which is attributable, to the income which may be taxed in the Islamic Republic of Iran.
  • (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.