Elimination of Double Taxation
In both Contracting States double taxation shall be eliminated as follows:
(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, then the first Contracting State shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in the other Contracting 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 the other Contracting State.
(2) Where in accordance with any provision of this Convention income derived by a resident of a Contracting State from the other Contracting State is exempt from tax in that State, that Contracting State may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.