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ARTICLE 22
Method for the Elimination of Double Taxation
(1) Double taxation shall be eliminated as follows:
- (a) In the Islamic Republic of Iran, where a resident of the Islamic Republic of Iran derives income which, in accordance with the provisions of this Agreement, may be taxed in South Africa, the Islamic Republic of Iran shall allow as a deduction from the tax on the income of that resident, an amount equal to the tax paid in South Africa on that income. 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 to the income which may be taxed in South Africa.
- (b) In South Africa, the income tax of the Islamic Republic of Iran paid by residents of South Africa in respect of income taxable in the Islamic Republic of Iran, in accordance with the provisions of this Agreement, shall be deducted from the taxes due according to South African fiscal law. Such deduction shall not, however, exceed an amount which bears to the total South African tax payable the same ratio as the income concerned bears to the total income.
(2) Where in accordance with any provision of the Agreement income derived by a resident of a Contracting State is exempt from tax in that State, such State may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.