background image
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.

ARTICLE 23

Methods for Elimination of Double Taxation

(1) In China, double taxation shall be eliminated as follows:

  • Where a resident of China derives income from Iran, the amount of tax on that income payable in Iran in accordance with the provisions of this Agreement, may be credited against the Chinese tax imposed on that resident. The amount of the credit, however, shall not exceed the amount of the Chinese tax on that income computed in accordance with the taxation laws and regulations of China.

(2) In the case of the Islamic Republic of Iran, double taxation shall be eliminated as follows:

  • (a) Where a resident of the Islamic Republic of Iran derives income which, in accordance with the provisions of this Agreement, may be taxed in the Peoples Republic of China, the first-mentioned State shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in the People’s Republic of China. Such deduction shall not, however, exceed that part of the 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 People’s Republic of China.
  • (b) Where in accordance with any provision of the Agreement income derived by a resident of the Islamic Republic of Iran is exempted from tax in the People’s Republic of China, such State may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.