Method for the Elimination of Double Taxation
(1) Where a resident of a Contracting State derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in the other Contracting State, the first-mentioned State shall allow:
- (a) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in that other Contracting State, and
- (b) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in that other Contracting State.
Such deduction in either case 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 or the capital.
(2) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of a Contracting State is exempted from tax in that State, such State may notwithstanding the exemption, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital.
(3) The tax payable in a Contracting State mentioned in paragraphs 1 and 2 of this Article shall be deemed to include the tax which would have been payable but for the tax incentives granted under the laws of that Contracting State and which are designed to promote economic development.
(4) For the purposes of this Article, the term "tax" shall not include any amount which is payable in respect of any default or omission in relation to the taxes to which this Agreement applies, or which represents a penalty imposed relating to those taxes.