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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) In the case of Kazakhstan, double taxation shall be avoided as follows:

  • (a) Where a resident of Kazakhstan derives income which, in accordance with the provisions of this Convention, may be taxed in the U.A.E., Kazakhstan shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in the U.A.E.
  • The amount of the tax to be deducted pursuant to the above provision shall not exceed the tax which would have been charged on the same income in Kazakhstan under the rates applicable therein.
  • (b) Where a resident of Kazakhstan derives income, which in accordance with the provisions of this Convention, shall be taxable only in the U.A.E. Kazakhstan may include this income in the tax base but only for purposes of determining the rate of tax on such other income as is taxable in Kazakhstan.

(2) In the case of the United Arab Emirates:

  • (i) Where a resident of the United Arab Emirates derives income, which in accordance with the provisions of this Convention may be taxed in Kazakhstan, the United Arab Emirates shall allow as a deduction from tax on income of that person an amount equal to the tax on income paid in Kazakhstan.
  • (ii) Such deductions in either case shall not exceed that part of income tax, 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 Contracting State.
  • (iii) Where in accordance with any provision of the Convention income derived by a resident of a Contracting State is exempt from tax in that Contracting State, such Contracting State may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.
  • (iv) For the purposes of paragraph (1) of this Article, profits, income and capital gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other Contracting State.