ARTICLE 23
Elimination of Double Taxation
(1) In the Islamic Republic of Iran, double taxation shall be eliminated as follows:
Where a resident of the Islamic Republic of Iran derives income or owns capital which in accordance with the provisions of this Agreement may be taxed in Russia, the Islamic Republic of Iran shall allow:
- (a) As a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Russia;
- (b) As a deduction form the tax on the capital of that resident, an amount equal to the capital tax paid in Russia.
Such deduction in either case shall not, however, exceed the part of the income tax or capital tax as computed before the deduction is given, which is attributable as the case may be to the income or the capital which may be taxed in Russia.
(2) In Russia, double taxation shall be eliminated as follows:
- Where a resident of Russia derives income or owns capital which in accordance with the provisions of this Agreement may be taxed in the Islamic Republic of Iran, the amount of tax on that income or capital payable in the Islamic Republic of Iran may be credited against the tax imposed in Russia. The amount of credit, however, shall not exceed the amount of the tax on such income or capital computed in accordance with the laws and regulations of Russia.
(3) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of a Contracting State is exempt from tax in that Contracting State, such Contracting State may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital.