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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 25

Elimination of Double Taxation

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

  • (a) In the case of Angola: Where a resident of Angola derives income which, in accordance with the provisions of this Agreement, may be taxed in the UAE, Angola shall allow as a deduction from the tax on the income of that resident an amount equal to the income tax paid in UAE. Such deduction shall not, however, exceed that part of the income tax as computed before the deduction is given, which is attributable, to the income or the capital, which may be taxed in the UAE.
  • (b) In the Case of the UAE: Where a resident of UAE derives income which, in accordance with the provisions of this Agreement, may be taxed in Angola, UAE shall allow as a deduction from the tax on the income of that resident an amount equal to the income tax paid in Angola. Such deduction shall not, however, exceed that part of the income tax as computed before the deduction is given, which is attributable, to the income or the capital, which may be taxed in Angola.

(2) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of a Contracting State is exempt from tax in that State, such State 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 purposes of the application of the credit method under paragraph (1) of this Article, income tax paid in either UAE or Angola, shall be deemed to include any amount which is payable as Angolan or UAE tax, but was not taxed due to an exemption or reduction of tax granted under UAE or Angola law.