Elimination of Double Taxation
(1) Double Taxation shall be eliminated in the Contracting States as follows:
- (a) where a resident of a Contracting State derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in the other Contracting State, the first-mentioned State shall allow:
- (i) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in that other State;
- (ii) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in that other State.
- (b) such deduction in either case shall not, however, exceed that part of the 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.
(2) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of a Contracting State is exempt from tax in that State, such State may nevertheless, in calculating the amount of tax on the remaining income or capital of that resident, take into account the exempted income or capital.