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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.


Method for Elimination of Double Taxation

(1) Where a resident of a Contracting State derives income or items of income referred to in Articles 10, 11 or 12 of this Convention, or profits or gains which under the laws of the other Contracting State and in accordance with this Convention may be taxed in the other Contracting State, then the first-mentioned State shall allow as a deduction from the tax on income, items of income, or profits or gains of that resident an amount equal to the tax paid in other Contracting State.

(2) However, such deduction shall not exceed that portion of the tax on income, items of income, or profits or gains, calculated prior to the deduction, corresponding to the taxable income computed in accordance with the taxation laws and regulations of the other Contracting State.