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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 of Elimination of Double Taxation

(1) Where a resident of a Contracting State derives income or owns capital, which in accordance with the provisions of this Agreement may be taxed in the other Contracting State, the first-mentioned State shall allow:

  • (a) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in that other State;
  • (b) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in that other State.

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 that other State.

(2) Such deduction in either case shall not,, exceed that part of the tax on income, as computed before the deduction is given, which is attributable as the case may be to the income which may be taxed in that other State.

(3) Where in accordance with any provision of this Agreement income derived by a resident of a Contracting State is exempt from tax in that State, such State may nevertheless, in calculating the amount of the tax on the remaining income of such resident, take into account the exempted income.

(4) For the purposes of paragraph (1) of this Article, profits income owned by a resident of 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 Contracting state.

(5) For the purposes of paragraph (1) of this Article, where the income arising in a Contracting State is exempt or taxed at a reduced rate in that State, for a limited period of time in accordance with the laws and regulations of that State, then the tax on such income which has been exempt or taxed at a reduced rate in that State shall be credited against the tax on income owing in the State where the beneficial owner of this income is a resident.

The competent authorities of the Contracting States shall consult each other regarding the mode of application of the provisions of this paragraph.