ARTICLE 22
Elimination of Double Taxation
(1) Where a resident of a Contracting State derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in the other Contracting State, the first-mentioned State shall:
- (a) allow as a deduction from the tax on the income of that resident an amount equal to the tax on income paid in that other State;
- (b) allow as a deduction from the tax on the capital of that resident an amount equal to the tax on capital paid in that other State.
Such deduction shall not, however, exceed that part of the income tax or capital tax, as computed before the deduction is given, which is appropriate to the income or capital, as the case may be, which may be taxed in that other State.
(2) Where in accordance with any provision of the Convention income derived or capital owned by a resident of a Contracting State is exempt from tax in that State, such State may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital.