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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

Double taxation shall be avoided as follows:

(1) Where a resident of a Contracting State derives income or has capital which is taxable in the other Contracting State under the provisions hereof, the first-mentioned State shall exempt such income or capital from tax subject to the provisions of Paragraphs (2) and (3) of this Article.

(2) Where a resident of a Contracting State derives items of income under the provisions hereof, which are taxable in the other Contracting State, the first-mentioned State grants a discount on the taxes levied on the income of the said resident in an amount equivalent to the tax paid by the other State. Such discount may not exceed in any way whatsoever the tax charged before applying such discount with respect to the items of income generated from such other State.

(3) Where, according to the provisions hereof, the income generated or the capital owned by a resident of a Contracting State is exempted from tax therein, the said State, for the purpose of calculating the amount of tax imposed on the remaining income or capital of such resident, may take into consideration the exempted income or capital.