ARTICLE 22
Elimination of Double Taxation in the State of Residence
(1) Tax shall be determined in the case of a resident of the Federal Republic of Germany as
follows: Subject to the provisions of German tax law regarding credit for foreign tax, there shall be allowed as a credit against German tax payable in respect of income which, according to this Agreement, may be taxed in the United Arab Emirates, the United Arab Emirates tax paid under the laws of the United Arab Emirates and in accordance with this Agreement.
(2) Where in accordance with any provisions of this Agreement income derived by a resident of the Federal Republic of Germany is exempt from tax in the Federal Republic of Germany, the Federal Republic of Germany may nevertheless in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.
(3) Tax shall be determined in the case of a resident of the United Arab Emirates as follows:
Where a resident of the United Arab Emirates derives income which, in accordance with the provisions of this Agreement, may be taxed in the Federal Republic of Germany, the United Arab Emirates shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in the Federal Republic of Germany;
That deduction shall not however exceed that part of the income tax, as computed before the deduction is given, which is attributable, as the case may be, to the income which may be taxed in the United Arab Emirates.