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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 24

Avoidance of Double Taxation

Double Taxation may be avoided if:

(1) If a resident in a Contracting State receives income that shall be taxed in the other Contracting state in accordance with the provisions thereof; the first-mentioned Contracting state shall permit a deduction from income tax of such resident of an amount equal to the tax on income paid in the other State. Such deduction, in any case, may not exceed, that portion of the tax on income calculated prior to the deduction.

(2) If an income gained by a resident in a Contracting state is exempted in such state, according to the provisions thereof, the Contracting state, while computing the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital.

(3) For the purpose of income tax discount in the Contracting state, the tax paid in the other Contracting state will include the due tax in the other Contracting state but it was exempted or reduced by such Contracting state in accordance with the tax incentive legislations.