background image
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 23

Methods for Elementing Double Impositions

(1) Where a resident of a Contracting State receives income which, in accordance with the provisions of this Agreement, is taxable in the other Contracting State, the first State, subject to the provisions of paragraph (2), shall, on the tax he shall deduct from the resident's income a deduction of an amount equal to the income tax paid in that other State. However, this deduction may not exceed the portion of the income tax, calculated before deduction, corresponding to the income taxable in that other State.

(2) For the purposes of the application of the provisions of paragraph (1), exemptions and reductions of taxes of a resident of a Contracting State in respect of taxable income in that State, for a specified period, under the domestic law of that State relating to fiscal incentives shall be deemed to constitute payment of the said taxes, and shall be deducted from any taxes levied on the same income in the other Contracting State.

(3) Where, in accordance with any provision of this Agreement, income derived by a resident of a Contracting State is exempt from tax in that State, the State may nevertheless, in computing the amount of the tax on the remainder of that resident's income, take into account exempt income.