ARTICLE 23

Elimination of Double Taxation

The double taxation shall be eliminated as follows:

• (a) In the Portuguese Republic:
  • (i) Where a resident of Portugal derives income which, in accordance with the provisions of this Convention may be taxed in the Czech Republic, Portugal shall allow as a deduction from the tax on the income of that resident an amount equal to the income tax paid in the Czech Republic. Such deduction shall not, however, exceed that part of the income tax as computed before the deduction is given, which is attributable to the income which may be taxed in the Czech Republic;
  • (ii) Where in accordance with any provision of the Convention income derived by a resident or Portugal is exempt from tax in this State, Portugal may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.
• (b) In the Czech Republic:
  • (i) The Czech Republic, when imposing taxes on its residents, may include in the tax base upon which such taxes are imposed the items of income which according to the provisions of this Convention may also be taxed in Portugal, but shall allow as a deduction from the amount of tax computed on such a base an amount equal to the tax paid in Portugal. Such deduction shall not, however, exceed that part of the Czech tax, as computed before the deduction is given, which is appropriate to the income which, in accordance with the provisions of this Convention, may be taxed in Portugal.
  • (ii) Where in accordance with any provision of the Convention or the domestic law income derived by a resident of the Czech Republic is exempt from tax in this State, the Czech Republic may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.