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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

Avoidance of Double Taxation

(1) Where a resident of a Contracting State receives income which, in accordance with the provisions of this Convention is taxable in the other Contracting State, the first-mentioned State shall grant, on the tax that it levies on the income of this resident, a deduction of an amount equal to the income tax paid in that other State.

This deduction, however, cannot exceed that portion of income tax, calculated prior to such deduction, corresponding, as the case may be, to income subject to tax in that other State.

(2) Where, in accordance with any given provision of this Convention, the income that a resident of a Contracting State receives is exempt from tax in that State, it may, nevertheless, take into account the exempted income for calculating the tax amount on the remaining income of this resident.