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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 Elimination of Double Taxation

(1) Where a resident of a Contracting State derives income which, in accordance with the provisions of this Convention, may be taxed in the other Contracting State, then the first-mentioned Contracting State shall allow as a deduction from the tax of that resident, an amount equal to the tax on income paid in that other Contracting State.

However, such deduction must not exceed that portion of tax on income calculated before granting the deduction pertaining to income which may be taxed in that other Contracting State.

(2) For the purposes of allowing a deduction provided in paragraph (1) of this Article, the taxes paid in the other Contracting State shall include such taxes which would otherwise have been paid in that other Contracting State, but which are exempted or reduced in accordance with the laws pertaining to special tax incentives for encouraging investment in that other State.