Elimination of Double Taxation
(1) Where a resident of a Contracting State derives income which, in accordance with the provisions of this Agreement, may be taxed in the other Contracting State, the first-mentioned State shall allow, subject to the provisions of paragraph 2, as a deduction from the tax on the income of that resident an amount equal to the income tax paid in that other State. However, such deduction shall not exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income which may be taxed in that other State.
(2) As regards the application of the provisions of paragraph 1, the exemptions and tax reductions of which benefits a resident of a Contracting State for a given period, in accordance with the domestic legislation of that State for tax incentives, are deemed to be worth payment of such taxes, and shall be deductible from the tax payable on such income in the other Contracting State.
(3) Where, in accordance with any provision of this Agreement, income derived 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 of such resident, take into account the exempted income.