ARTICLE 23

Elimination of Double Taxation

(1) In the Czech Republic, double taxation will be avoided in the following manner:

• (a) Where a resident of the Czech Republic derives income which, in accordance with the provisions of this Convention, may be taxed in Thailand, the Czech Republic shall allow as a deduction from the Czech tax on the income of that resident an amount equal to the tax paid in Thailand. Such deduction shall not, however, exceed that part of the Czech tax, as computed before the deduction is given, which is attributable to that income.
• (b) For the purposes of sub-paragraph (a), the term "tax paid in Thailand" shall be deemed to include the amount of the Thai tax which would have been paid if the Thai tax had not been exempted or reduced under any special incentive law designed to promote economic development in Thailand, effective on the date of signature of this Convention or which may be introduced hereafter in modification of, or in addition to, the existing law.

(2) In Thailand, double taxation will be avoided in the following manner:

• (a) Where a resident of Thailand derives income which, in accordance with the provisions of this Convention, may be taxed in the Czech Republic, Thailand shall allow as a deduction from Thai tax on the income of that resident an amount equal to the tax paid in the Czech Republic. Such deduction shall not, however, exceed that part of the Thai tax, as computed before the deduction is given, which is attributable to such items of income.
• (b) For the purposes of sub-paragraph (a), the term "tax paid in the Czech Republic" shall be deemed to include the amount of the Czech tax which would have been paid if the Czech tax had not been exempted or reduced under any special incentive law designed to promote economic development in the Czech Republic, effective on the date of signature of this Convention or which may be introduced hereafter in modification of, or in addition to, the existing law.