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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

Methods for Elimination 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 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. However, such deduction must not exceed that portion of the income tax, calculated prior to the deduction, corresponding to the taxable income in the other Contracting State.

(2) Where the income derived by a resident of a Contracting State is exempted from tax 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 shall, when calculating the amount of tax on the remaining portion of the income of that resident, take into account the exempted income.