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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) In the case of the resident of the U.A.E., double taxation shall be avoided as follows:

  • (a) Where a resident of the U.A.E. derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in the Bosnia and Herzegovina, the U.A.E. shall allow:
    • (i) as a deduction from the tax on the income of that resident, an amount equal to the tax on income paid in the Bosnia and Herzegovina;
    • (ii) as a deduction from the tax on the capital of that resident, an amount equal to the tax on capital paid in the Bosnia and Herzegovina.
  • Such deduction in either case shall not, however, exceed that part of the income tax or capital tax, 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 the Bosnia and Herzegovina.
  • (b) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of the U.A.E. exempt from tax in the U.A.E., the U.A.E. 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.

(2) In the case of the resident of Bosnia and Herzegovina, double taxation shall be avoided as follows:

  • (a) Where a resident of a Bosnia and Herzegovina derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in the U.A.E., Bosnia and Herzegovina shall allow:
    • (i) as a deduction from the tax on the income of that resident, an amount equal to the tax on income paid in the U.A.E.;
    • (ii) as a deduction from the tax on the capital of that resident, an amount equal to the tax on capital paid in the U.A.E.
  • Such deduction in either case shall not, however, exceed that part of the income tax or capital tax, 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 the U.A.E.
  • (b) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of Bosnia and Herzegovina exempt from tax in Bosnia and Herzegovina, Bosnia and Herzegovina 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 allowance as a credit in a Contracting State the tax paid in the other Contracting State shall be deemed to include the tax which is otherwise payable in that other state but has been reduced or waived by that state under its legal provisions for tax incentives.