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ARTICLE 25

Elimination of Double Taxation

Double Taxation shall be eliminated in the Contracting States as follows:

(I) In case of Albania:

  • (1) Where a resident of Albania derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in the United Arab Emirates, Albania shall allow:
    • (a) as a deduction from the tax on that income of that resident, an amount equal to the income tax paid in the United Arab Emirates;
    • (b) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in the United Arab Emirates.
  • Such deduction in either case shall not, however, exceed that part of the Albania tax in income or capital, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital, which may be, taxed in United Arab Emirates.
  • (2) Where in accordance with any provision of the Convention income derived or owned capital by a resident of Albania is exempt from tax in Albania, Albania 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.
  • (3) For the purpose of this paragraph 1 and 2, profits, income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Agreement shall be deemed to arise from sources in that other State.

(II) In case of the United Arab Emirates:

  • (1) Where a resident of United Arab Emirates derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in the Albania, United Arab Emirates shall allow:
    • (a) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in the Albania;
    • (b) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in the Albania.
  • Such deduction in either case shall not, however, exceed that part of the Albania tax in income or capital, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital, which may be, taxed in Albania.
  • (2) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of United Arab Emirates is exempt 'from tax in United Arab Emirates, United Arab Emirates may nevertheless, in calculating the amount of tax on the remaining income or capital of that resident, take into account the exempted income or capital.
  • (3) For the purpose of this paragraph 1 and 2, profits, income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Agreement shall be deemed to arise from sources in that other State.