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Morocco - Sao Tome Tax Treaty (2016, not yet in force) — Orbitax Tax Hub

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.


Elimination of Double Taxation

(1) Where a resident of a Contracting State derives income which, in accordance with the provisions of this Convention, may be taxed in the other Contracting State, the first-mentioned State shall, subject to the provisions of paragraph 2, allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in that other State. Such deduction shall not, however, 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) For the purposes of the provisions of paragraph 1, tax exemptions and reductions enjoyed by a resident of a Contracting State in respect of income taxable in that State for a determined period of time pursuant to the domestic legislation of that State concerning tax incentives shall be deemed to have been actually paid, and shall be deducted from the tax potentially assessed on the same items of income in the other Contracting State.

(3) Where in accordance with any provision of this Convention 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.