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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 23

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 Ukraine, but shall allow as a deduction from the amount of tax computed on such a base an amount equal to the tax paid in Ukraine. 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 Ukraine.

(2) In the case of a resident of Ukraine, double taxation shall be eliminated as follows: In accordance with the provisions of the law of Ukraine regarding the elimination of tax payable in a territory outside Ukraine (which shall not affect the general principles of that paragraph), on the Slovak tax payable under the laws of the Slovak Republic and in accordance with this Convention, whether directly or by deduction on profits, income or capital which is taxable from sources in Slovakia, shall be allowed as the deduction against any Ukrainian tax computed by reference to the same profits, income or capital by reference to which the Ukrainian tax is computed. Such deduction in either case shall not exceed that part of 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 that other State.