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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 22

Elimination of Double Taxation

Where a resident of a Contracting State derives income which, in accordance with this Convention, may be taxed in the other Contracting State, the first mentioned State shall grant, on the tax that it levies on the income of that resident, a deduction an amount equal to the income tax paid in that other State. This deduction may, however, not exceed the portion of the income tax, calculated prior to the deduction, corresponding to taxable income in that other State.

Where, in accordance with any provision of the Convention, income derived by a resident of a Contracting State is exempt from tax in that State, the latter may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.