Article 25 - Elimination of double taxation

Elimination of double taxation via exemption or tax credit mechanisms to prevent double taxation on cross border income.

Elimination of double taxation is achieved by: (a) exemption in the resident State where income or capital is taxable under the Convention in the other State, with the resident State allowed to apply its normal rates to remaining income; and (b) inclusion of such income in the resident State's tax base with a deduction equal to tax paid in the other State, limited to the portion of domestic tax attributable to that income. 'Tax paid in the other State' includes amounts reducible by domestic reliefs in that State.