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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.


Elimination of Double Taxation

(1) Subject to the provisions of the laws of a Contracting State regarding the elimination of double taxation, in the case of a resident of that State, double taxation shall be eliminated as follows:

  • This Contracting State, when imposing taxes on its residents, may include in the tax base upon which such taxes are imposed the items of income or of capital which according to the provisions of this Agreement may also be taxed in the other Contracting State, but shall allow as a deduction from the amount of tax computed on such a base an amount equal to the tax paid in that other State. Such deduction shall not, however, exceed that part of the tax of the first-mentioned State, as computed before the deduction is given, which is appropriate to the income or capital which, in accordance with the provisions of this Agreement, may be taxed in the other Contracting State.

(2) Where in accordance with any provision of the Agreement 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.