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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

Double taxation shall be avoided in the following manner:

(1) Where a resident of a Contracting State derives income which, in accordance with the provisions of this Convention is taxable in the other Contracting State, then the first-mentioned State shall allow as a deduction from the income tax of that resident an amount equal to the income tax paid in that other State.

However, such deduction must not exceed that portion of the income tax of the first-mentioned Contracting State, calculated prior to the deduction, corresponding to the taxable income in that other State.

(2) Where the income derived by a resident of a Contracting State is exempt from tax in that Contracting State under the provisions of this Convention, then the first-mentioned Contracting State shall, when calculating the amount of tax on the remaining income of such resident take into account the exempted income.