*ARTICLE 23
Elimination of Double Taxation
(1) In the case of a resident of Ukraine, double taxation shall be eliminated as follows:
Where a resident of Ukraine derives income or owns property which, in accordance with the provisions of this Convention, may be taxed in the Czech Republic, Ukraine shall allow:
- (a) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in the Czech Republic;
- (b) as a deduction from the tax on the property of that resident, an amount equal to the property tax paid in the Czech Republic.
Such deduction in either case shall not, however, exceed that part of the income tax or property tax, as computed before the deduction is given, which is attributable, as the case may be, to the income or the property which may be taxed in the Czech Republic.
(2) Subject to the provisions of the laws of the Czech Republic regarding the elimination of double taxation, in the case of a resident of the Czech Republic, double taxation shall be eliminated as follows:
- 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 or of property which according to the provisions of this Convention may also be taxed in Ukraine, but shall allow as a deduction from the amount of tax computed on such a base an amount equal to the tax paid in Ukraine. 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 or property which, in accordance with the provisions of this Convention, may be taxed in Ukraine.
(3) Where in accordance with any provision of the Convention income derived or property 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 property of such resident, take into account the exempted income or property.