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ARTICLE 23

Elimination of Double Taxation

Double taxation shall be eliminated as follows:

(1) Subject to the laws of the United Arab Emirates where a resident of the United Arab Emirates derives income which in accordance with the provisions of this Agreement may be taxed in the Malaysia, the United Arab Emirates shall allow as a deduction from the tax on income of that person an amount equal to the tax on income paid in Malaysia before the deduction is given, which is attributable to the income which may be taxed in the United Arab Emirates.

(2) Subject to the laws of Malaysia regarding the allowance as a credit against Malaysian tax in any country other than Malaysia. U.A.E. tax payable under the laws of the United Arab Emirates and in accordance with this Agreement by a resident of Malaysia in respect of income derived from the United Arab Emirates shall be allowed as a credit against Malaysian tax payable in respect of that income. Where such income is a dividend paid by a company which is a resident of United Arab Emirates to a company which is a resident of Malaysia and which owns not less than 15% of the voting shares of the company paying the dividends, the credit shall take into account U.A.E. tax payable by that company in respect of its income out of which the dividend is paid. The credit shall not, however, exceed that part of the Malaysian tax, as computed before the credit is given, which is appropriate to such item of income.

(3) For the purposes of paragraph 1, taxes which have been relieved or reduced in Malaysia by virtue of special incentive laws for the promotion of the economic development of Malaysia or any other provisions which may subsequently be introduced in Malaysia in modification of, or in addition to, those laws or by virtue of the provisions of this Agreement shall be deemed to have been paid and shall wherever applicable be allowed as a credit in the United Arab Emirates in an amount equal to the tax which would have been paid if no such relief or reduction had been made.