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 22
Elimination of Double Taxation
In both Contracting States double taxation shall be eliminated as follows:
- (1) Where a resident of a Contracting State derives income which, in accordance with the provisions of this Agreement, may be taxed in the other Contracting State, then the first Contracting 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 other Contracting State; such deduction in either case 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 other Contracting State.
- (2) Where in accordance with any provision of this Agreement, income derived by a resident of a Contracting State is exempt from tax in that State, this Contracting State may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.