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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 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 Latvia, India shall allow as a deduction from the tax on the income of that resident, an amount equal to the tax paid in Latvia.
    • 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 Latvia.
    • (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 Latvia:
    • (a) Where a resident of Latvia derives income which, in accordance with the provisions of this Agreement, has been taxed in India, Latvia shall, subject to the provisions of subparagraphs (b) and (c), exempt such income from tax.
    • (b) Where a resident of Latvia derives income which in accordance with the provisions of paragraph (2) of Articles 10, 11 and 12 may be taxed in India, Latvia 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 the income which may be taxed in India.
    • (c) Where in accordance with any provision of the Agreement income derived by a resident of Latvia is exempt from tax in Latvia, Latvia may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.