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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 23

Avoidance of Double Taxation

(1) Where a resident of a Contracting State derives income that, in accordance with the provisions of this Convention, may be taxed in the other Contracting State, then the first-mentioned Contracting State shall allow as a deduction from the income tax of that resident, an amount equal to the income tax paid in that other Contracting State. In any case, such deduction must not exceed the portion of tax on income calculated before granting the deduction pertaining to income which may be taxed in that other Contracting State.

(2) Where the income derived by a resident of a Contracting State is exempt from taxation in that Contracting State under the provisions of this Convention, and where such income is subject to taxation in the other Contracting State, then the first-mentioned Contracting State, when calculating the amount of tax on the remaining portion of the income of that resident, shall take into account the exempted income.

(3) For the purposes of allowing a deduction on obligatory taxes imposed in a Contracting State, the taxes paid in the other Contracting State shall include such obligatory taxes of that Contracting State. An exemption or reduction of such taxes shall be applied according to the laws pertaining to tax incentives for encouraging investment in that State.