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ARTICLE 23
Elimination of Double Taxation
(1) It is agreed that double taxation shall be avoided in accordance with the following paragraphs of this Article.
- (1) In the case of Venezuela:
- (a) where a resident of Venezuela derives income or owns capital, which, in accordance with the provisions of this Agreement may be taxed in the Islamic Republic of Iran, Venezuela shall allow as a tax credit from the Venezuelan tax on the income of that resident, an amount equal to the income tax paid in the Islamic Republic of Iran, according to the Venezuelan tax legislation;
- (b) the tax credit allowed under sub-paragraph a) of this Article shall not exceed that part of the Venezuelan income tax, as computed before the deduction is given, which is attributable to the income which may be taxed in the Islamic Republic of Iran.
- (2) In the case of the Islamic Republic of Iran:
- 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 Venezuela, 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 Venezuela.
- (b) as a deduction from the tax on capital of the resident, an amount equal to the capital tax paid in Venezuela.
- Such deductions in either case shall not, however, exceed that part of the income tax or capital tax as computed before the deduction is given, which is attributable to that 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.