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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

Methods for the Elimination of Double Taxation

The elimination of double taxation shall be as follows:

  • (1) Where a resident of a Contracting State derives items of income which are liable to tax in the other Contracting State in application of the provisions of this Convention, the first mentioned State shall grant a deduction of an amount equal to the income tax paid by such a resident in that State. This deduction shall in no case exceed the portion of the tax calculated before the deduction is carried out concerning items of income derived from that State.
  • (2) Where, by virtue of the provisions of this Convention, income received by a resident of a Contracting State or capital owned is exempt in that State, the latter may, in calculating the amount of tax on the remaining income or capital of such resident, take into account such income or capital.