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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 25

Elimination of Double Taxation

Double taxation shall be eliminated as follows:

  • (1) Where a resident of Contracting State derives income or gains which in accordance with the provisions of this agreement may be taxed in the other Contracting State, the first-mentioned Contracting State shall allow as a deduction from tax on income of that person an amount equal to the tax on income paid or should have been paid in the later mentioned Contracting State.
  • (2) Such deduction in either case shall not exceed that part of income tax or capital, 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.
  • (3) Where in accordance with any provision of the Agreement income derived or owned by a resident of a Contracting State is exempt from tax in that State may nevertheless, in calculating the amount of tax on the remaining income or of such resident, take into account the exempted income.