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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

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 Uruguay, India shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in Uruguay.
  • 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 Uruguay.
  • (b) Where a resident of India owns capital which, in accordance with the provisions of the Agreement may be taxed in Uruguay, India shall allow as a deduction from the tax on wealth of that resident an amount equal to the capital tax paid in Uruguay.
  • Such deduction shall not, however, exceed that portion of the tax as computed before the deduction is given, which is attributable to the capital which may be taxed in Uruguay.
  • (c) Where in accordance with any provision of the Agreement income derived or wealth owned by a resident of India is exempt from tax in India, India may nevertheless, in calculating the amount of tax on the remaining income or wealth of such resident, take into account the exempted income or wealth.

(2) In Uruguay:

  • (a) Where a resident of Uruguay derives income which, in accordance with the provisions of this Agreement, may be taxed in India, Uruguay 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 that portion of the tax as computed before the deduction is given, which is attributable to the income which may be taxed in India.
  • (b) Where a resident of Uruguay owns wealth which, in accordance with the provisions of the Agreement may be taxed in India, Uruguay shall allow as a deduction from the tax on capital of that resident an amount equal to the Wealth 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 the wealth which may be taxed in India.
  • (c) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of Uruguay is exempt from tax in Uruguay, Uruguay may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital.