background image
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 24

Elimination of Double Taxation

(1) In the case of a resident of the Slovak Republic, double taxation shall be eliminated as follows:

The Slovak Republic, when imposing taxes on its residents, may include in the tax base upon which such taxes are imposed the items of income which according to the provisions of this Convention may also be taxed in Romania, but shall allow as a deduction from the amount of tax computed on such a base an amount equal to the tax paid in Romania. Such deduction shall not, however, exceed that part of the Slovak tax, as computed before the deduction is given, which is appropriate to the income which, in accordance with the provisions of this Convention, may be taxed in Romania.

(2) In the case of a resident of Romania, double taxation shall be eliminated as follows:

  • (a) when a resident of Romania derives income or has capital which in accordance with the provisions of this Convention are taxable in Slovakia, then Romania shall exempt from tax this income or capital-excepting the income mentioned in sub- paragraph (b)-and shall take into account in determining the tax rate the total income derived, applying this tax rate only on the remaining income;
  • (b) when a resident of Romania derives items of income which in accordance with the provisions, of Articles 10, 11, or 12 may be taxed in Slovakia, than Romania shall allow as a deduction from the tax on income of that resident an amount equal to the tax paid in Slovakia. However, such deduction shall not exceed that part of the tax, as computed before the deduction is given, which is attributable to such items of income from Slovakia.